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Electronic Delivery of Error Resolutions

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Can someone tell me if there is a requirement to deliver the error resolution jointly with the statement? We are in the process of rolling out e-statements, but due to system limitations, our customers will only be able to view their statement information pulled from our system, and not the error resolution (currently preprinted on the back of the paper statement). We plan to have an error resolution link "in case of errors, please click here" on the page that leads them to their statement. Are we OK on this?

There are two options in the regulation. Both are described in Section 205.8(b). The first is an annual notice (long form), which can be delivered as a stand-alone notice. The second is a short-form notice, that can be delivered on or with the periodic statement.

I haven't seen any statement from the Fed that agrees or disagrees that the "on or with" requirement would be met if you included the link you've described in the landing page that leads the customer to the statement. To be on the safe side, you could use the long form disclosure, which need not be on or with the statement. It's actually more informative, and only a few bytes more of storage would be needed for it.

This could all be moot, if your demonstrative consent handshake only covered statements. Although the short form notice that you were printing on the back of your statement paper was on the same piece of paper as the statement, it's not part of the statement itself. However, if your e-sign agreement includes other notices and disclosures relating to the account, you should be OK.

First published on 4/26/10

First published on 04/26/2010

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