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E-Statement Conversion - Signatures on File?

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Question: 
We are going to start converting customers to an e-statement program. From what I can tell the only compliance issue is with the disclosure of e-statement viewing procedures and notification. When contacting our customers by phone we are verifying identity and signing them up for electronic statements. Do we need an actual signature on file?
Answer: 

If by "customers" you mean "consumers" (not businesses) you need demonstrable consent from each customer before you can legally convert him/her to e-delivery. Wholesale conversion of portfolios is impossible, and it is neither possible to obtain consent by telephone nor by traditional paper agreements. Since you seem to be new to e-delivery, I would highly recommend that you get a copy of this seminar that Andy presented on the subject. It should be helpful to everyone involved in your project.

First published on BankersOnline.com 1/05/09

First published on 01/05/2009

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