EnrollMobile Deposit & Online Banking Disclosures

Posted By: Jenny Roberts

EnrollMobile Deposit & Online Banking Disclosures - 03/17/20 10:03 PM

What kind of disclosures or terms & conditions are required for customer to consent to to enrolling in mobile banking? Also to enroll in online banking?
Posted By: BrianC

Re: EnrollMobile Deposit & Online Banking Disclosures - 03/17/20 10:48 PM

Online banking would require Reg E disclosures as outlined in 1005.7.

Terms and conditions are legal documents that outline the responsibilities of each party.
Posted By: Richard Insley

Re: EnrollMobile Deposit & Online Banking Disclosures - 03/17/20 11:38 PM

Service agreements are contracts, so you should make every effort to develop them under guidance from your legal counsel--even in these uncertain times. All Reg. E disclosures must be "in writing", and that means ESIGN if you want/need to deliver them electronically.
Posted By: ckme

Re: EnrollMobile Deposit & Online Banking Disclosures - 09/01/20 07:09 PM

To clarify, the online banking agreement for an already established account does not trigger e-sign, but enrolling in e-statements would? Would there be any requirements agreement that could possibly cross the line (ie. cut off times, transfer limits, etc)?

Thanks!