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#726103 - 05/03/07 03:48 PM Amendment to Regulation E
SDGuy Offline
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Joined: Jun 2005
Posts: 77
South Dakota
I heard that there has been a proposed amendment to Reg E but have been unable to find it on the net. Can someone link me to it or provide some details? Thank you.

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eBanking / Technology
#726162 - 05/03/07 04:48 PM Re: Amendment to Regulation E SDGuy
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,333
Cape Cod
Sure. Go to our Top Stories page and then locate the April 2007 archived page. You'll find a summary and links in the entries for April 30.

Oh, what the heck! Click HERE. It's the second entry on the page.
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John S. Burnett
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#726165 - 05/03/07 04:53 PM Re: Amendment to Regulation E John Burnett
John Burnett Offline
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John Burnett
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By the way, you can receive a daily email that announces changes like this. Just click HERE and select the Compliance Briefing (and any other briefings that you're interested in.
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#736036 - 05/18/07 06:13 PM Re: Amendment to Regulation E John Burnett
RebekahL CRCM Offline
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RebekahL CRCM
Joined: Feb 2003
Posts: 775
Big Sky Country
OK, so I've read the proposed rules, and I'm wondering how the changes might affect "pushed" e-statement delivery. The proposed rules will allow banks to forgo sending statement notification for the "pulled" method of delivery, but I can't tell from the proposed language if "demonstrable consent" will change for pushed statements. I'm thinking of writing a comment letter for clarificaiton on this point. Gurus... any thoughts?
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Me, Type A? Maybe - I'm not done analyzing it yet.

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#736352 - 05/18/07 08:30 PM Re: Amendment to Regulation E RebekahL CRCM
John Burnett Offline
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John Burnett
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Cape Cod
The change to the regulation does not change anything regarding the E-Sign Act. Demonstrable consent continues to be required, whether statements are pushed or pulled. The only substantive changes are the elimination of the requirement that the email address must be one outside the control of the bank, the requirement for email notice of disclosure/statement availability, the requirement for redelivery for bounced emails, and the requirement for at least 90-day availability at the location where you told customers a disclosure would be available.

But E-Sign didn't get changed in any way.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#736439 - 05/18/07 08:56 PM Re: Amendment to Regulation E John Burnett
RebekahL CRCM Offline
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RebekahL CRCM
Joined: Feb 2003
Posts: 775
Big Sky Country
Thank you, John!
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Me, Type A? Maybe - I'm not done analyzing it yet.

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