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Reg E/Z Disclosures Required on ODP e-statements?

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Question: 
We have just started with e-statements. Our overdraft protection statements have the same account number as the checking account it is attached to and are created at the same time as checking accounts. Are the Reg E and Z disclosures that we provide with each ODP statement going to be required on every ODP e-statement? Is that also true for the checking statements for Reg E?
Answer: 

If the communication you call an "e-statement" replaces the paper statement(s) you currently use to transmit account information and the disclosures required by Regs. E and Z, then the "e-statement" must meet the same standards that applied to the discontinued paper statement(s). Conversely, if the "e-statement" is added and the paper statement continues without interruption, then the paper statement satisfies the regulatory requirements and the "e-statement" is courtesy information. Your only concern would be that the courtesy copies must not contradict the "official" statements.

First published on 11/05/2017

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