My bank wants to send Estatements. We are comfortable with the Esign and Reg E requirements. The question is whether, when an Estatement notification email bounces back, the customer can call us to give us an updated email address, or whether the customer must give us an email address "in a manner that demonstrates the ability to receive electronic disclosures" (e.g., go to our website to update the email address). I am familiar with the info-vault materials such as http://www.bankersonline.com/technology/guru2005/gurus_tech040405a.html , but those discussions do not directly address this issue. Thank you for your thoughts.

You would have to test the second address to ensure it is working and has the capacity to receive the email. Should be easy. Often the backup plan is print and snail mail. Possibly a fee would be triggered here as well.