Answer:
Having them sign up for Internet banking is fine. The problem of demonstrable consent comes into play if you plan on making your disclosures to them electronically. Delivery of disclosures in an electronic form as your primary means of delivery will require E-SIGN compliance, including demonstrable consent. That cannot be completed while the customer is in your lobby unless they have the device with them which they’ll be using, such as a smart phone, tablet or laptop.
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Learn more about Andy Zavoina’s E-SIGN, It’s Value Pandemic or Not webinar.
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