We are wanting to start offering this service to our customers. Are there any special disclosure requirements in regard to offering this service? I appreciate any information.

It's common for banks that sign customers up for SMS alerts to include a notice on the solicitation or sign-up page to the effect that "Standard text message charges may apply."

You are not making required disclosures so E-SIGN isn't an issue. Just ensure your data is input correctly as you don't want to send info to the wrong number. Generally these are generic and do not disclose private info anyway, but still a test is a good thing. The only other thing I'd add is that they know they can or cannot reply to the message. In many cases you would have them contact you via a different channel in the event they were being phished.

This may seem obvious, but don't include the account number in the message, whether it's an SMS or email. If you have to refer to the account (because there's more than one of them, for example), truncate the number.

One other thing. If the message is about a balance level, I'd rather get a message saying it's a balance level alert, rather than a message saying "The balance has exceeded $5,000"

Reviving an old thread - This is assuming they have signed up for these types of alerts, or have given consent to receive text messages, correct? (TCPA implications) If my institution wants to send a customer a text message letting them know someone has sent them money via a mobile Zelle type transaction, but they have not "signed up" for this type of service themselves, they just happen to be on the receiving end, would we be prohibited from sending them this type of text? In this scenario the receiver has provided the sender their phone number, and the sender and receiver are both customers of the bank.

I know there have been various court cases recently regarding TCPA and consent. I would greatly appreciate any insight, if any.

Thanks!