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Delivery of E-statement Disclosures

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Question: 
Do we need to provide e-statement disclosures in electronic format only, or if a customer signs up in a branch can we deliver the disclosure in print format either by handing out or by mail by the next business day?
Answer: 

The provisions of E-SIGN stipulate that you must receive affirmative confirmation from the customer to receive disclosures electronically in a manner that demonstrates their ability to actually receive the disclosures in the manner contemplated. I take this to mean that if you anticipate delivering statement disclosures electronically by sending an e-mail message to the customer with a link to a web site where they can access the statement and disclosures, then in signing the customer up, your process must include sending them a sample e-mail message that directs them to a website that contains a sample disclosure and have them somehow confirm that they have received the sample disclosure and want to proceed.

First published on BankersOnline.com 10/23/06

First published on 10/23/2006

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