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E-statement Disclosures

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Question: 
What disclosures do we need for e-statements? Are there any sample disclosures out there?
Answer: 

Generally you need the same disclosures as you do for paper statements. There is no difference in terms of content. You do need to make sure that provisions of E-SIGN or UETA have been complied with in order to allow the electronic disclosures to substitute for written disclosure requirements. E-SIGN or UETA have their own set of up-front disclosures that must be made and agreed to by the customer to allow for electronic disclosures.

One point you can consider with e-statements. Ordinarily most banks have opted to put the short form billing rights notice (Reg Z) and the short form error resolution notice (Reg E) on each statement rather than having to incur increased postage to send an annual long form notice required under each reg. In an e-statement environment, you may be able to just as easily provide an annual long form notice electronically as you could provide a monthly short form notice, so you could opt to go that route.

First published on BankersOnline.com 5/22/06

First published on 05/22/2006

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