Are there any guidelines or prohibitions against using unsecured email to communicate with customers regarding adverse circumstances such as past due loans, overdrafts, etc.? Specifically work related email addresses.

There are none specific that I know of, but I wouldn't do it. I don't have a cite, but you can't send a collection letter on a postcard. To many people can read it. The same would hold true for an e-mail.

You could be liable for definition of character... or something like that.

If it work related email it is going through the employer (in a sense) to get to the employee. I would not recommend this method unless the customer consents to it (and I am sure they will do that!)

Thanks for your reply, I was hoping you would come through with at least an opinion. I didn't think that there had been any specific guidance, but wasn't sure or if it could be implied through other issuances. I was very uncomfortable with it, since most email is not secure and like you said could be damaging to character if sent to their place of employment and ended up in the wrong hands, or is that the wrong p/c

When the FDIC stopped in last time, they made it a point to ask me to post the non-private nature of email, including advising customers not to include account information in email. If you take that one step further, it seems logical that they would have something not so good to say about a bank that decided to send account information via email, especially negative information.

Which is why I always shake my head and wonder why they send us the 314(a) and Control lists this way.

Here is the cite.

15 U.S.C. Sec. 1692f, Unfair Practices
(7) Communicating with a consumer regarding a debt by post card.