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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