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Bank Address/Phone Info on E-statements

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Our institution sends E-statements to its members. With regard to 12 CFR 205.9(b)(5) and listing the address and telephone number for inquiries, is this required to be directly on the statement, or can we include this within our online banking module or via a message to the member when we send notification that their statement is available?

Because Reg E states: "The statement shall set forth the following information, as applicable...", I would include it on the statement, and not on a separate email wrapper or logon page. My issue here would be that if the consumer saves the periodic statement or prints it, will he automatically have the contact information that he is intended to have? If I print my statement and balance it later, who do I call if I find an error? I may not know.

First published on 10/12/09

First published on 10/12/2009

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