Our bank is looking into customer statements sent by email. The customer must sign-up for this service. The bank proceeds to email the customer that their statement is ready for email pick-up. The customer gains access to their statement from a secure bank site with a password.

If any bank does this practice,please share what you place on your website and how you disclose your "error resolution " to the customer? How long do you retain the email statement for customer pick-up? Thanks

The error resolution shouldn't be to tough. Either have it as an additional page or possibly a reference to it. You can refer to where the statement is, why not the error resolution notice. Consider too, going to an annual notice instead of the abbreviated one.

As to retention, I'd hold it 90 days minimum.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

I know I am beginning to sound like a Richard Insely clone, but don't forget to review the requirements of the E-Sign Act! Even though the E-Regs were postponed, the E-Sign Act is still alive and kicking, and any disclosures would certianly fall under that Act.
Leslie

Thanks for everyone's help...I have another part on the email statements...what happens if the customer neglects to pick up their statement within the alloted time period or can't pick it up by email? Is this the customer's responsibility or must the bank get the statement to the customer? I would believe we could build this in the agreement but is it legal to do so?

This is one of the current hang-ups that delayed the mandatory compliance date of the regulations. While I too believe it could be made a contractual issue, others did not necessarily agree and want to ensure taht adequate consumer protections are built in.

The current regulations, which are optional at this point, say that you have to use a non-proprietary e-mail notification system. That is, you can't just notify them with a message when they log into Internet banking.

If you get return e-mail, you'd need to use an alternate address. Likely this means you'll have to snail mail them, possibly inserting a copy of the statement to promote timely delivery. Remember those cost savings you were going to see with e-delivery, it just left.

So the bottom line to your question is, there isn't a solid answer or enough folks doing this to to be considered a best practice. And whatever you do may have to be changed when the regulations do get finalized. So whatever you do, make it flexible.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Lela- I don't understand what you mean by "email pickup." Does the customer use a web browser to "visit" the statement/disclosure at a secure URL on your website, or somehow trigger the delivery of the statement by sending an email message? If you're posting the statement at a URL and sending an alert message, the e-Regs dictate a 90-day availability period & don't suggest any responsibility to see if the address was visited.

Thanks,Richard for clarifying that point. I am hearing two different concepts as the "tech" staff states we will send an email notification to the customer. The other concept you addressed.

My next concern is the customer pick-up of their statement after the email notification and the 90 days out on the secured website. Do we as a bank have a responsiblity to get the statement to the customer? If so, what regulation requires that statement delivery after the 90 days?

E-mail notification followed by 90 days' posting on the WWW IS delivery to the customer.

Holding the statement (electronically) for 90 days is the e-equivalent of printing the statement and holding it (at customer's request) at your branch. Remember that the regulation requires that you make the statement available, and if the customer fails to pick it up, you have no duty to snail-mail it.