E-statements Delivery and Non-Delivery

E-statements and non-delivery if the customer's email address comes back with this notification. I am reading REG E section 213.6 and NACHA rules where if this occurs, a delivery method must be completed for the disclosure or statement delivery to the customer. I am wondering how others are approaching this issue.

I would like to place the email address notification process as the this section looks like the bank must take the action. Please comment. Thank you.

Your actions may be based on why it was returned. Did the receiver exceed an allowed memory ceiling which may make this deliverable tomorrow or is the address no longer valid?

I would actually recommend resending either to a different e-mail address if you have one, or of going the snail mail route (with extra postage come month end).

Our agreement for e-statement delivery states that it is voided when we get return e-mail for any reason. The customer goes back to snail mail and will have to reapply if they want to resume e-statements.

Current eStatement delivery notifications are "messaged" within our online banking application - so its not possible for them not to be delivered... Now is it possible that the customer never logs in to online banking to pickup their message or eStatement - yes.

-V

Victoria- If you are communicating the availability of monthly disclosures inside a proprietary system, how do you comply with the e-Regs?

The interim final regs specifically addressed this and prohibit it. This was major concern from many of us who commented. The notification cannot require them to log onto your system.

In one sense I see their reasoning, but not in another. I won't go into those explanations here, but in a way, that is a requirement for a specific technology which E-Sign prohibits. Will it change, who knows.