Answer by Richard Insley:ESIGN required you to disclose the procedures your customer must follow to report EMA changes. Assuming nothing has changed on your end, you have done what the law requires and need take no further steps.
Good customer service may dictate additional efforts, however. Pay attention to the amount of time (spelled m-o-n-e-y) it takes to obtain the new EMA and you'll see why some banks follow a system that:
- sets a higher price for paper statements,
- charges the reduced e-delivery price as long as things go without a hitch, and
- automatically switches the customer to paper delivery and higher pricing when the customer fails to live up to his/her obligation to notify you of EMA change.
Answer by Andy Zavoina:The original poster may be thinking of the interim-final rules that would have required that they attempt redelivery. Those rules are gone.
First published on BankersOnline.com 12/08/08