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E-statements and Reg E

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Question: 
We offer e-statements to customers. When someone signs up, he is provided the Reg E disclosure electronically at that time. Do we need to have a link to the disclosure for future reference, and specifically, the Reg E part of reviewing a statement for errors? Would a link be sufficient for people to access at any time if the language is not included on each statement?
Answer: 

Reg E gives two different alternatives for providing error resolution notices. These are noted at 205.8(b). The first is you can mail or deliver at least once each calendar year, an error resolution notice similar to the model form in Appendix A (Model Form A-3(a)). As an alternative, you can include a notice similar to the abbreviated Model form in Appendix A (Model Form A-3(b)) on each statement.

Most institutions opting to deliver paper statements have traditionally opted for the abbreviated version on each statement, because they could be pre-printed on the statement stock and nobody ever had to worry about missing including it, and you didn't have additional printing and mailing costs once a year to send out the long form. Now with the advent of e-statements, you may decide that the annual notice option is preferable. If you go that route, you'll just need to deliver the annual notice in conformance with E-SIGN as prescribed in Section 205.4(a)(1). Of course, you can always leave the short form notice on the e-statements and comply that way too. If you don't include the language on each statement, then my understanding is that you would have to mail or deliver (either paper or electronically in compliance with E-SIGN) the annual notice - simply having a link to the notice would not suffice.

First published on BankersOnline.com 12/06/10

First published on 12/06/2010

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