The bank is doing a Core conversion. Do we need to have our customers re-enroll (consent) for eStatements again in the new system?

Section 7001(c)(1)(D) says -- "after...consent...if a change in the hardware or software requirements needed to access or retain electronic records creates a material risk that the consumer will not be able to access or retain a subsequent electronic record that was the subject of the consent, the person providing the electronic record...(must march the customer through a new demonstrable consent "handshake.") It's up to your bank to make the "material risk" determination. I'm not aware of any litigation or guidance that elaborates on this requirement.

Thank You!!