E-Sign and Fees

One of the requirements of an E-Sign disclosure is to:

Inform the consumer how the consumer may nonetheless request a paper copy of a
record and whether any fee will be charged for that copy.

Should this be stated as a specific dollar amount in the disclosure? or will "We may charge you a reasonable service for the delivery of paper copies...." be sufficient?

I believe most banks will use the hourly account research fee or the per copied item fee that is already on the account initial dislosure/fee shcedule. Therefore,disclosing as "a reasonable charge" will be ok.

Thanks for your input.

The E-sign disclosure itself has to indicate whether there will be a fee for a paper copy, but does not have to say what that fee is. In the spirit of transparency, however, I do recommend that you provide the fee amount with other fees disclosed either with new account paperwork or on your website. If it happens to be the same as the fee you're disclosing a per copied item fee, so much the better.

John,

"In the spirit of transparency".. I like that.


Thanks for quick response and reassurance.