Online Reg E Disclosures

Answer by John Burnett:

I assume that the "abbreviated Reg. E disclosure" to which you refer is the short-form error-resolution notice.

If you plan to provide customers e-statements, you have two choices to comply with the requirement to provide the error-resolution notice. Either you send it to your e-customers annually (paper or electronically), using the long form notice, or you provide the short form with or in their monthly statement. If you are planning to notify customers of the availability of their statements via e-mail and allow them to access the statements on a secure server, I do not recommend including the error-resolution notice as part of the e-mail notice. It would not comply with the "on or with the monthly statement" requirement. Make sure the statement itself conforms to Reg. E and Reg. DD requirements.

If you plan to "push" statements in encrypted form, be certain the customer can both accept and read the encrypted messages, and that whatever you are sending includes all of the Reg. E. and Reg. DD requirements.