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Vendor Guru Q&A - Operations

Electronic Management of SAR Files

Latest Operations - E-Sign Topics

E-SIGN Requirement for Accessing Acct Statements

11/11/2018

We have had an internet banking platform for several years and are preparing to roll out the mobile banking interface to internet banking customers. Through both the online platform and the mobile platform, customers are able to access account statements. We currently also provide paper statements to all customers, including those who are enrolled in internet banking. Customers are not able to choose between paper statements and electronic statements in the internet banking platforms (i.e. internet banking customers with access to electronic statements also receive a paper statement). Are we required to be compliant with E-SIGN due to the internet banking customers being able to access account statements electronically, even though they are receiving paper statements?

E-SIGN's Demonstrable Consent​ Requirement​

03/18/2018

We are in the beginning stages of implementing online account opening. We are working with the vendor regarding ​E-SIGN​ acknowledgment. Currently, the test environment is configured so that the customer receives a validation code in an email. All of the required disclosures are attached to this email as a pdf. I am of the opinion this does not comply with ​E-SIGN's demonstrable consent​ requirement​. Their response to my concern is as follows: Our other clients have concluded that by obtaining consumer consent to ​E-SIGN and confirming the consumer received the email (using the verification code) reasonably demonstrates that the consumer can access the information in the electronic form. The disclosures in the email are PDF files. PDF format is an ISO standard that enable users to exchange and view electronic documents, independent of the environment in which they were created or the environment in which they are viewed or printed, while preserving content and visual appearance. Adobe relinquished control of the PDF format in July 2008 to the International Organization for Standardization to encourage the propagation and dissemination of this common technology. Today all modern operating systems, including mobile, support display of PDF files. Adobe Acrobat Reader is not a requirement to open and view PDF files. Thus, my question is would you deem this configuration to meet ​E-SIGN consent requirements?

Bad idea to have two signatures required

08/27/2017

A father and son wanted to open an account today where two signatures would be required on each check. It’s extra work for them, but does it really matter to us?

Who opens e-statements and who doesn’t

05/29/2016

If we send e-statements are we required to monitor whether they are being read, and if the customer is not opening them, do we have to revert back to paper?

E-SIGN and demonstrable consent

05/15/2016

We like having customers sign up for Internet banking when they open their accounts. Is this acceptable for E-SIGN, or is more needed?

E-Notices for NSF and Overdraft Protection As Well As CD Maturity and Renewals

09/13/2015

Are electronic notices permitted for NSF and overdraft protection communication as well as CD maturity and renewals? Customers signing up for e-statements would automatically get these via e-notice, with an e-mail being issued to advise the customer of the e-notice. The customer would then log on to view it.

Requirements for Mailing eStatements

05/26/2014

If a business or personal account holder does not look at their checking account e-statement, what are the bank's requirements in mailing the statement?

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IRA Client CD Deposit-Exception to Penalty (Reg D)

12/09/2018

If an IRA client (over 59 1/2) receives an automatic IRA distribution from their retirement CD, and then comes to a branch and makes an additional over the counter withdrawal from the same CD within six days after the automatic distribution, is that considered a violation of Reg D? We are debating this due to the fact that the footnote in the Reg D language, that indicates the exceptions to charging a penalty, was placed after the first statement about CD deposits. It was not placed after the next statement regarding partial withdrawals. So do the exceptions only apply to withdrawals made following the deposit, or do they apply to partial withdrawals as well?

Accept Copies of Original Short Certificate?

12/09/2018

For estate accounts we require the customer to present an original death certificate and an original short certificate. We will make a copy of the death certificate and return it to the customer, if requested. However, we do require to keep the original short certificate. Should we be accepting copies of both rather than the originals? (A Short Certificate is a legal document that shows the decedent’s name and date of death. It will also show the name of the Executor/Executrix who has been named to handle the affairs of the estate.)

Category for Business DC Dispute w/Merchant

12/09/2018

I am working a business debit card dispute (merchant dispute) and I am unsure on whether I can pursue the chargeback, or if I should deny the claim. The cardholder is disputing hotel charges stating "the resort had continuous power outages, my room wasn't cleaned. I was assured I would only charged for food services..." Will this fit into category "Services Not Rendered" or "Misrepresentation; Condition" or neither because it is a matter of quality and the dispute will need to be handled between the cardholder and the merchant?

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