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Online Banking: Is a paper statement required?

We are new to internet banking. We have our customer statements as part of our online product. The statement has a complete copy of our mailed version. We have customers asking us to stop their paper copy. What are the rules and to start this what would need to do.

Answer by Andy Zavoina
Following E-Sign requirements, the customer needs to meet certain requirements such as demonstrating the ability to receive these. Review E-Sign, especially Section 101(c). Then look at 205.17 (Reg. E), especially (c), to ensure proper delivery.

This isn't a difficult process but may be more than you want for a single customer.

Make sure when you say the statement is the same, that you are including either the abbreviated Reg. E error disclosure commonly on the back of statement or the annual notice sent as a stuffer, in your disclosures.


Answer by Richard Insley
You must also comply with Reg. DD and possibly Reg Z (if your deposit statement serves as a periodic disclosure for an overdraft protection credit product.) See Sections 230.6 and 230.10.

First published on 07/07/03

First published on 07/07/2003

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