Requiring e-statements on employee accounts

Answered by:

Question:

Since we cannot require employees to accept e-statements for their deposit accounts, we are trying to develop incentives that will highly encourage them to sign up for the e-delivery. Presently, employees are not charged a service charge for their accounts. Can we change this policy for existing and future employees, so they will receive an account free of charge if they use e-statements? Otherwise they will be charged the normal service charge incurred by customers without violating regulations, thus start assessing a service charge on all existing employee accounts unless they sign up for e-delivery.

Answer:

Answer by John Burnett:Sure, you can do that. You have a free account that includes e-delivery, and a fee account that includes snail mail delivery. Just make sure that when you sign employees up for the e-account, you make them step through the demonstrable consent routine that is mandated by the ESIGN act. If they will receive the e-stuff at an outside email address - a home email, for example - ensure that they are doing the ESIGN Handshake away from the bank, and ensure that your ESIGN Handshake routine includes all forms of written notices that might be involved with the account, including change in terms, annual/periodic Reg. E error resolution notices, etc. Just because they're employees doesn't mean they aren't consumers, so you want to make sure that you dot all your i's and cross all your t's for compliance.

Answer:

Answer by Andy Zavoina:I completely agree, with one caveat. I would encourage employees to use a home email address if they have that capability, otherwise you are forcing them to do personal banking on the bank's clock, checking accounts, reviewing/balancing statements, printing, etc., and this only pays them to bank with you and risks exposure of their information as they leave it on a screen, at the printer, etc.

First published on BankersOnline.com 4/07/08