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E-SIGN Validation

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Question: 
If we have the customer sign-in to internet banking before submitting email requests such as address changes to a central location - Do we still need to implement E-Sign?
Answer: 

E-Sign is required in order for you to deliver disclosures to a customer electronically, which are required to be "in writing." If you are doing this, and substituting bits and bytes for paper and ink, then E-Sign is required, and demonstrable consent is required as a condition in advance of actual delivery when dealing with consumer customers. If you are not substituting bits and bytes for "written" disclosures, then no. You are simply adding an additional delivery channel, and not replacing one. Address changes require no federally required disclosure so E-Sign isn’t an issue.
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First published on 05/10/2020

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