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NSF notices via email?

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Question: 
Our operations department wants to consider implementing the following: all customers who have signed up for e-statements will receive any NSF notices via email. We have an encryption system (Zixmail) available, so they would likely go out that way. Would this be covered under our existing e-statement disclosure, or should we have those customers sign a second authorization?
Answer: 
  • First, I am aware of no requirement to send these notices at all. It is a customer service/awareness issue.

  • Second, it depends on the specificity of your E-Sign agreement and what you said would be encompassed. If Zixmail would be new, I would say this is a substantive change and would require demonstrable consent all over again.

  • Third, I would hate to make a change like this without telling the customers.

First published on BankersOnline.com 12/06/10

First published on 12/06/2010

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