09/01/2024
Is an email consent disclosure considered "written consent" for ChexSystems? I have a lender who would like to email the ChexSystems consent disclosure to account owners and use their reply to the email as proof of consent. Does this satisfy the requirement that the consent be in writing?
05/14/2023
Does an online bank (such as Ally Bank or go2bank) have to provide customers with an Image Replacement Document (IRD) when checks deposited via mobile Remote Deposit Capture (mRDC) are returned?
If no, does it then become the responsibility of the payee to work with the maker of the check to recoup the funds?
10/31/2021
How can banks organize their documents that are already in electronic format?
08/15/2021
How do banks generate and distribute notice letters?
11/08/2020
Should we print and scan documents that are already in electronic format to get them into our imaging system?
05/05/2019
We currently offer eStatements to our online customers but have a very low adoption rate. We seem to be running into issues with getting customers signed up because we cannot assist them at the bank unless it is on their own device. Being compliant with the E-Sign Act says the customer must "reasonably demonstrate that they can access information in the electronic form that will be used to provide the information that is the subject of the content". What is the way around this so that we can get them signed up at account opening or by utilizing a lobby computer? I know of other institutions that do this but am not finding how that is in compliance. Any help would be appreciated!
04/14/2019
Most consumers only use a mobile device these days to access their online banking. Is enrolling and accepting e-statements on a mobile device compliant with a consumer demonstrating consent?
02/10/2019
My bank is getting ready to convert to a new online banking program. During this process, I have found that we have the option to allow some features as well as turn off others.
Should we allow business accounts to be viewed under the individual’s personal login? For example, Jane Doe has personal accounts at CNB. She also owns “Jane's Closet, LLC” and has her business accounts at CNB too. She has 100% ownership of the LLC. Would you allow Jane to see Jane's Closet’s account under her personal log in? If not, what are the reasons why you would not allow this?
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?
11/05/2017
We have just started with e-statements. Our overdraft protection statements have the same account number as the checking account it is attached to and are created at the same time as checking accounts. Are the Reg E and Z disclosures that we provide with each ODP statement going to be required on every ODP e-statement? Is that also true for the checking statements for Reg E?