We are currently investigating using e-statements. I'm looking for advice on how you notifed your customers that "e-statements are now available" and if there have been any unforseen problems in complying with regulations. I am familiar with some regs being vague and subject to interpretation. Any input would be appreciated.

ESIGN is your biggest challenge, and the best place for your implementation team to start is this webinar that Andy presented recently. You'll find a wealth of good advice for everyone who has a role in your e-delivery project. The regs are not vague, but they have changed.

We began with a "Coming Soon" on our website and internet banking sites. Also, included as a statement message and Coming Soon posters in the branch. Had the branches sellingit at account opening time also. We also emailed our internet banking customers when it went live.

Like Richard said the biggest hurdle is to make sure you get the handshake (demonstrate consent) part correctly on your site.

I hope they were selling internet banking, or selling, but not closing e-statements. It is difficult at best to handle demonstrable consent at the new accounts desk.

I'd say it's impossible unless the customer brings his/her laptop and uses it to sign up & consent.

That and a remote connection or using a mobile device was my thought as well. It is possible, but wouldn't be likely or common.

Many banks in my area now have internet cafes where a customer can use online banking at their local branch (sounds stupid to me... why would I go to the branch to use online banking??) I suppose the best thing about this is new accounts people can demo the internet banking software using the customer's actual accounts. If this is the case, I figure it is probably the only consistent way to get the electronic "handshake" from the customer at account opening.

Piggybacking on the OP.... Do you need to send an email to let the member know that their e-statement is now available or can there be a general message on the website homepage that statements are available?

There is no specific requirement for notifying customers that a statement is available. When you have only one statement cycle for e-statement customers, a website notice might be workable. But if you break cycles up, a general notice wouldn't work very well.

A lot of systems are set up to send email notices, but that's not specifically required. Customers who get a lot of e-statements from non-bankers (cable, telephone, gas and other utilities, or credit card accounts) might be used to getting a notice, and might prefer it as a reminder. But again, it's not required.

I am a bit new to ebanking. Regarding estatements, I understand that we are not required to provide email notification to borrowers that their statements are available, however, if we do, are there any specific requirements as to what has to be included in the email?

No. Presumably, such notices would state that a periodic statement is now ready to be viewed and downloaded, and provide a reminder about where to find it (or a link). I'd recommend that account numbers not be included in the message (unless you only show the last four or five digits), and that you include a reminder that the customer is responsible for prompt examination of the statement and timely notice of any errors.

Our bank just finished rolling e-stmts out after much research, many questions on BOL and some good training (thanks Andy Z!) Of course along the way I learned about demonstrable consent and passed that requirement along to my team members and management as we worked on the process.
When rolling it out to the bankers, there was OUTRAGE over not being able to sign the customer up at the bankers desk. I can understand that, when they walk out the door, you may lose them on it. I mentioned making customer computers available near the coffee and cookies and big screens for customers to access and print their statements whenever they wanted. The idea was not well received but the President wants to designate a banker's computer in each location for the customers to use along the same lines as I suggested. I see huge problems with this - privacy of electronic and paper customer records, inconvenience on the part of the customer and the banker - having to wait for each other to finish. Even after my response, my sup wants me to continue to research this to see if we should proceed (or until they get the answer they think they want.) So please, let me have it - anyone else have any input I can take back to management?

Unfortunately, that's the law.


Although I'm not aware of any litigation that would clear this up, ESIGN envisions the customer being in full control of the process of receiving and using e-documents. Since the locations where these PCs would be located are not open to the public 24/7, the customer does not have control of bank-owned PCs.

Another good point, thank you.