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#2141032 - 08/07/17 04:17 PM Pay Loan from website
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Hi!

We want to have a feature added to our website where a certain subset of loans can be paid via our website. These borrowers do not have accounts with us other than their loans. They will need to "sign up" - meaning set up a User Name and establish a password, add in their deposit account information (acct #, routing #) and we will send the ACH to draft the payment. We do not intend to send statements, notices or disclosures through this channel. Strictly, loan payment.

Is there any E-SIGN requirement? I think not, but need a vote of confidence.
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eBanking / Technology
#2141035 - 08/07/17 04:36 PM Re: Pay Loan from website Tesla
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Is there any E-SIGN requirement? No

But you will want to establish additional security aspects so you know they are paying the loan with an account they own.
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#2141037 - 08/07/17 04:43 PM Re: Pay Loan from website Tesla
Tesla Offline
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Posts: 3,726
Thanks Randy!
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#2141048 - 08/07/17 04:55 PM Re: Pay Loan from website Tesla
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
ESIGN only becomes relevant when some other federal law or regulation requires you to send a document "in writing." Your original post doesn't mention the need for delivery of disclosures & therefore ESIGN shouldn't even be a consideration.
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#2141053 - 08/07/17 05:01 PM Re: Pay Loan from website Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Is there any guidance or best practices anywhere related to how to verify the account belongs to the borrower? The question has come up what if the parents give permission for the kid to hit their account for payments.
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.

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