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Notification Requirements & Posting Periodic Statements On Web Site

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We post periodic statements on our web site instead of emailing them. Do we have to email customers each time the statements are posted and tell them they have been posted? If they have more than one account with us do we have to send multiple emails?

Reg E, in the Fed's attempt to implement E-sign, requires that you notify your customer when the statement is ready for access. The current version of Regs. E & DD require that any notice you send to your customer concerning a disclosure/statement be sent to a "public" e-mail address (the customer's own e-mail, rather than a proprietary secure e-mail box that the bank controls). Of course, all of these Fed rules were delayed as to mandatory compliance dates. That leaves compliance sort of optional (but compliance with the Fed rule will keep you out of any trouble).

If multiple account statements are ready at the same time, there appears to be nothing in Section 205.17 or its Commentary to prevent combining the notices into one. But the notice must include a reference to the account(s) involved. If the customer's checking and savings accounts are combined into one statement, you may need to say something like "We have made statements on your accounts listed below available at [Web site address].
First account number (or checking)
Second account number (or savings)"

Notice that you don't have to identify the account number if the customer only has one account of a type. You can refer to the account type instead.

First published on 06/16/03

First published on 06/16/2003

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