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E-Statement Format Change

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We have changed our e-statement format from HTML to PDF. Should we have notified our customers of the change?

Absolutely. In fact, because this is a substantive change the demonstrable consent steps should have been processed all over. I would venture to say that more PCs can read an HTML statement than a PDF. If you are pushing these they are, I assume, encrypted PDFs. Some of your customers may not be able to read those PDFs and this puts you at risk for Reg E statement delivery requirements as well as Reg E and DD change notices that may have been communicated via the statements.

You should consider extending Reg E error resolution and delaying changes that were in motion. Re-send the statements that were delivered incorrectly and get your demonstrable consent steps processed so you can legitimately make the change.

Internal procedures should also be evaluated to avoid this type of a breakdown in the future. More research should have been done in advance. Chalk this up as a lesson learned.

First published on 1/05/09

First published on 01/05/2009

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