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#573576 - 06/23/06 02:19 PM EStatement
WheezeKid Offline
100 Club
Joined: Jun 2004
Posts: 137
New Jersey
We are planning to issue electronic statements via customer email with a pdf attachment. For verifiable consent, is it enough to send a "pre-email" without a pdf attachment to ensure customer access, or should a pdf attachment be included in the "pre-email"?

Also, does anyone have and be willing to share model language relative to required ESign disclosures?

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eBanking / Technology
#573577 - 06/23/06 04:59 PM Re: EStatement
Banking Bard Offline
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Joined: Jul 2005
Posts: 191
Kentucky
I believe that customer consent must also prove their ability to view the statement.

Sending an email without the PDF would likely not qualify since it does not prove that the customer has the equipment and means necessary to view the PDF attachment.
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The above is my opinion, and is frequently valued at USD 2ยข or less.

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#573578 - 06/23/06 05:08 PM Re: EStatement
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
You should send a test statement. The customer can open it and click a link, as an example, that takes them to your site and you then verify that they can receive, open and follow directions on it. YOu could also have a name and number in it for them to call and verify with.

Short of having them open an encrypted file, you only proved otherwise that the mail didn't bounce back at you.
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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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