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#27570 - 08/09/02 08:22 PM Electronic disclosures
PABanker Offline
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PABanker
Joined: Dec 2000
Posts: 491
Blue Ball, PA 17506
If you use this medium for regulatory disclosures that require time frames. When do you consider that time frame beginning...when the customer opens the email or when the disclosure notification is sent by the bank? I was wondering if this governed by E-sign and UETA ? Lastly how would a bank monitor these time frames?

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eBanking / Technology
#27571 - 08/09/02 09:38 PM Re: Electronic disclosures
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,749
On the Net
Delivery means when you sent it, just as with snail mail. You can't control and realistically can't determine when a message was received. It was available for receipt (assuming no backbones were down, etc.) And just because a machine received a message, that wouldn't mean a user was there to read it.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#27572 - 08/10/02 02:07 AM Re: Electronic disclosures
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
The Fed's 2001 amendments/commentaries to Regs B, E, M, Z, and DD specifically indicate that delivery occurs when you send the message. For other laws & regs you'll have to make your case.
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