Can we "require" an email address to be provided in order to establish/open/apply for either a deposit or loan product? Therefore, if no email address is provided we don't establish the relationship?

And can you direct me as to where I can find that information if there are any restrictions?

I, like many potential customers, would just tell you to go pound sand and I would take my business elsewhere.

You need to consider the potential for disparate impact when talking about lending.

For rlcarey: Ancient memories have stirred; can a lender require a phone number?

Anon: I have no problems giving a new bank a phone number, perhaps even my own. I will not give them an e-mail address because as soon as I do they start sending me inane e-mails telling me that they are my friend and what great service they give. Unsolicited e-mails are as welcome to me as unsolicited phone calls and they are not emblematic of good service.

If a bank wanted to make provision of an e-mail address a condition of doing business I would either say I didn't have one or just make one up on the spot.

Ken: you may be thinking about Reg. B's prohibition regarding the use of personal telephone listing as a factor in making a consumer credit decision. The premise of that rule is that the practice has a disproportionately adverse effect on women. Since email addresses needn't reveal the owner's name or physical address (and cause a personal security risk), the existence or lack or an email address should not correlate with gender, and therefore Reg. B shouldn't be an issue.

Although discrimination may be off the list, that doesn't eliminate demographic concerns. Just guessing, I'd say the market segment least likely to communicate by email today would be one of the most attractive prospects for bank products: young people. This group is much more likely to rely on text messaging and social media and pay little attention to email. The same may be true for seniors...who have no interest in technology. Any marketing practice that disqualifies one or both of these groups is misguided.

Another marketing blunder would be to view email as a good cost-effective way to cross market additional products to existing customers. Promotional email messages are subject to the CAN-SPAM Act's opt-out requirement. Even though a bank may have working email addresses for 100% of its customers, any customer who want's to turn off the cross-marketing messages must be allowed to do so.

I do exactly this when a company, bank or not, requests my email and simply doesn't want to take no for an answer.

While most people have access to e-mails, the ones that generally might not are elderly (eyesight, or not raised with it), or low(er) income individuals where it might be too costly (certain protected classes make up a significantly higher proportion of the LMI groups).

For deposits, it does not yet matter, but for lending, I could see potential implications of disparate impact for age, race and ethnicity.