Our Mobile Banking product works like this:

Customer must first be a online banking customer.
Customer may enroll for the service only from within the online banking application.

The customer receives the Reg E notice when the account is opened, and receives another Reg E notice if the online banking is added later. Since the mobile banking application is actually part of the online banking product, will another Reg E notice need to go out when the customer enrolls if not in "close proximity" to the online banking product?

I would like to incorporate this disclosure into the signup procedure for mobile banking. The application displays our agreement which the customer must "Agree" to with a click. But would we have to jump through all the e-sign hoops to accomplish this?

I'm afraid I know the answer, but would like to know what everyone else is doing...

Bump

We're looking into providing Mobile Banking and have the same questions. How have you handled the Reg E question?

I'm wondering what everyone’s take is in regards to Tristan's Mom's question above.

"Our Mobile Banking product works like this:

Customer must first be an online banking customer.
Customer may enroll for the service only from within the online banking application.

The customer receives the Reg E notice when the account is opened, and receives another Reg E notice if the online banking is added later. Since the mobile banking application is actually part of the online banking product, will another Reg E notice need to go out when the customer enrolls if not in "close proximity" to the online banking product?"

I recently attended a webinar during which they stated "Mobile Banking", added as means to access an account, is considered a new access device and requires a new Reg E disclosure.


Thoughts?

If your mobile banking is merely a phone-phriendly (should it be fone-friendly?) version of your online banking, I think you can tweak your online disclosures a bit to include mobile access and consider them one service. But if mobile is appreciably different, or if there are different limits or restrictions that apply, I think you need to keep them separate for clarity's sake and provide a separate set of targeted disclosures when a customer signs up for mobile.