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#845286 - 10/30/07 03:35 PM Statements on CD Rom only
Analauditor Offline
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Joined: Aug 2005
Posts: 44
I have been asked by our operations folks if we can turn off paper statements to our business customers who are receiving statements in pdf format on CD rom.

Since the statements are for business accounts only, I don't have any Reg DD or Reg E worries. Therefore, I am concluding that we do not have to verify that the customer can actually open a pdf file, etc.

Am I on the right track? Any other worries?

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eBanking / Technology
#845768 - 10/30/07 08:21 PM Re: Statements on CD Rom only Analauditor
Andy_Z Offline
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Andy_Z
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On the Net
While those fed regs won't inhibit you, don't you want buy-in and acceptance from your customers? I think you'd still have check forgery/UCC issues and E-Sign requirements for change in terms notices and such.
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#845773 - 10/30/07 08:23 PM Re: Statements on CD Rom only Andy_Z
John Burnett Offline
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Cape Cod
There's no demonstrable consent rule in E-Sign for business customers. But I agree you'll want to assure yourselves that the business can actually use the CD-ROM. If not, they will be more valuable as coasters.
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