Is this permissible?

We currently comply with E-Sign...including demonstrable consent when our clients sign up for our Banking Online product. The terms and conditions indicate that the bank will provide disclosures electronically. The client accepts etc...documents are pdf..and so on and so on....
Can we provide notice to the client that Revised Disclosures (such as our revised account agreements) are available via the bank-mail tied to the banking online account...ie...the email message box found on the page when you log in (I know the requirement that the email not be bank controlled was never finalized, I think in 2007)...so I think we can use the bank-mail to inform the customer that the revised disclosures are available instead of sending to their personal email. The other option would be to put a Revised Disclosure Section in their Banking Online so that it is always available for them to click on and we thought we could color code it or flag it somehow to get their attention, but there wouldn't be an email notification....I'm not certain that would comply....any thoughts.

You have to stick with the e-delivery hardware, software, and document list to which you and your customers agreed. If you add an additional e-delivery method that isn't substantially the same as the previously agreed method, then you should probably put the customer through the appropriate consent process for the new method.

Account agreements may or may not be multi-purpose documents. If the revisions relate to EFTs and one document contains both the contract amendments and also any required Reg. E disclosures, then you must operate by the rules you & the customer accepted via the ESIGN consent process. If the "revisions" do not contain required federal disclosures, then you are free to follow any method allowed by your state's laws and agreed with the customer.