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Account Disclosures Upon Application Via Internet

When opening an account on the internet, what disclosures should be given to the applicant at time of application? This would be for checking, money market and CDs only.

Answer by Jim Bedsole: The timing requirements for disclosures do not change for accounts opened via the internet. They are the same as for accounts opened in the branch.


Answer by Richard Insley You're right about timing, Jim, but the tricky part comes when deciding which format you can or must use. For deposit accounts "opened" generally means "available for debit access". Following this standard, disclosure timing and format depends on the means of funding and activating the account. If the online opening process involves EFT or credit card charge, and does not require paper or a visit to the bank, then all account-opening disclosures will probably need to be e-delivered. On the other hand, if the customer must mail in an opening deposit and await a traditional new account kit in the mail, then there's time to deliver the account-opening disclosures on paper.

First published on 4/4/05

First published on 04/04/2005

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