Download E-Statement Sign Up Sheet Requirement

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Question:

Currently our bank requires our customers to download the e-statement sign up sheet online to demonstrate their capability to download and read their future e-statements. This extra step sometimes deters customers from signing up. Can we simply add wording onto the e-statement agreement stating something along the lines of- customer acknowledges their ability to read and download the e-statement? Everything I have read doesn't seem to clarify what customers can do to demonstrate their ability to access the e-statement.

Answer:

No. A "declaration" is not the equivalent of a "demonstration." Imagine a road test for a driver's license that could be skipped by any candidate who stated that s/he "acknowledges the ability to drive" an automobile! ESIGN does not explain in detail what steps constitute a successful demonstration of a consumer's capability to access e-documents. It's like the Supreme Court's test for obscenity--you'll know it when you see it.