We currently require all customers sign an application when signing up for Telephone banking. Other banks have open enrollment where they can call telephone banking and sign up right then. My question is....is there any requirement that we must have a signed application? I don't see anything in Reg E stating we must have a written application. My people would like to start open enrollment and as of now I can't find anything saying this is not permissible.

Reg E says we can not issue an access device without written or oral authorization from the cusotmer. Would this constitute oral authorization?

Mickey - I think it's fine (I hope) because we had an even less stringent method of enrolling in our 24 hour phone system. That said, at the suggestion of our outside auditors, we are switching and reuqiring a signature to sign up for the service, and adding voice authentication for pin resets as well.

The request need not be in writing to comply with the regulation. However, if it's not in writing, how can you document its existence? You need to consider that question before implementing "open enrollment" for issuing access devices, unless you will not impose any liability on the consumer for unauthorized use.