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Adobe Software Requirement Change: E-Statement

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Question: 
Our software vendor made a change in the software requirements for our customers to be able to open and read an E-statement. Our agreement with the customer when E-statements was launched advised the customer that they needed Adobe Reader 6.0 or higher to be able to read their statement. They now need 8.0 or higher to be able to read it; they can no longer view it in 6.0. Am I correct that this is a material change and 101(c)(1)(d) of ESIGN must now be complied with? My software vendor does not have the functionality in their e-statement product at this point to comply with 101(c)(1)(d), which is a another problem but they are also advising me that going from one version of Adobe Reader to another is in their opinion not a material change because when the customer attempts to open an estatement they will be prompted to download the latest version of Reader for free. I disagree, the customer may not be able to download it and under ESIGN they must demonstrate to the bank that they can still open and read an estatement.
Answer: 

Yes, your vendor has forced you into a position where Section 101(c)(1)(D) applies. I would demand that the vendor revert to the older software version until/unless you can "...again comply with subparagraph (C)" (demonstrable consent).

First published on BankersOnline.com 10/22/12.

First published on 10/22/2012

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