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!
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?
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?
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?
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?
Can an LLC or Corporation conduct telephone transfers from the account to a personal account or personal loan? I have been told that telephone transfers ARE allowed as long as proper verification measures have taken place. If an owner, or authorized signer on a business account needs to do a telephone transfer, they are allowed to do so, as long as they are verified to be on the account and their identity can be verified over the phone. Also this can only be done if a Resolution of Authority allowing the signers to execute all powers on an account has been signed. However, I have also been told that we should not allow this, but it is a bank decision on how to handle it. Can you please advise me on what the best practice should be?
Do you have to display "Member FDIC" on Facebook posts if you are simply saying "Check out this new checking product" and provide readers with a link that takes them to a page with full disclosures?
Is it a best practice to print and scan files already in email (digital) format?
Our new marketing director believes we have to be on Facebook, Twitter and other social media, and believes having employees writing and making the posts will make us more transparent and friendly to our customers. What risks do we face with all-employee access?
Our customer has appointed her daughter as her attorney-in-fact. Can the daughter set up Internet banking on her mom's account? The daughter/AIF is not listed as a joint owner of the account, and was appointed AIF after the account was open.