Our operations department wants to consider implementing the following: all customers who have signed up for e-statements will receive any NSF notices via email. We have an encryption system (Zixmail) available, so they would likely go out that way. Would this be covered under our existing e-statement disclosure, or should we have those customers sign a second authorization?
We are struggling with how to get customers to convert to e-statements and E-SIGN in general. We were considering converting all account to this, but the law doesn't really allow it. How are banks getting their customers to convert?
Marketing is working on our E-SIGN promotions and wants to know what the E-SIGN agreement will include. Is it just lending, deposits, or can it include both?
We are discussing changing our free checking account to include eStatements as a requirement of the account. To request paper statements would create a monthly fee. Can we still advertise this as a free checking account?
When reviewing our website, what are the main compliance issues we need to look for?
New Reg E Rules on Check Conversions, Payroll Cards
By BOL Gurus Andy Zavoina and John Burnett
I am chairman of our Compliance Committee and a question was raised by our deposit area. Our deposit area accepts stop payment requests via e-mail and through our PC Banking package. Their question is whether this constitutes a signature within the 14 days established by UCC 4-403 or is it a verbal arrangement that requires a signature. My response was that a signature would still be required within the 14 days on any stop payment accepted by these methods. Would you concur?