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Test Driving E-statements

Question: 
I have a question regarding the article <a href="http://www.bankersonline.com/technology/gurus_tech102003b.html">Test Drive Procedure on E-Statements</a>. The article indicates that we must send the customer a sample record/document using the same electronic method proposed to use for the disclosure/statement you wish to employ. The article further states that we must include within that record a piece of information that the consumer is unlikely to know without reading the record. We then must require the consumer to communicate that piece of information to you or your system. Receipt of the correct "key" from the consumer provides evidence the consumer has equipment to receive and display the record and the consumer can read it. Of course, this is in addition to the consumer's affirmative statement that he wishes to participate and all that other stuff that has to happen. We are in the process of implementing e-statements and our proposed process is this: Electronic statements and optical check images are already available to members logged in to our Web site, along with paper copies that continue to be mailed to the customer. However, if the customer wants to receive notice when their e-statement is ready for viewing (pull system versus a push system), they will click a button indicating that they want such notification. A disclosure containing all term and conditions will pop up at that point and the member will have to agree to. At that point, an email will be generated to the email address on file and paper statements will no longer be generated. The notification email will contain a hyperlink that when clicked, will take the customer to their e-statement where they'll be required to logon before reviewing the statement. Does this process, in your opinion, meet the requirements listed above? To my knowledge, there are no plans for anyone in our institution to ensure that the member either received the notification or was able to view the statement.
Answer: 

Answer by Richard Insley: No.

Answer: 

Answer by John Burnett: This is the deciding factor. You haven't completed the loop on the "demonstrable ability" routine.

First published on BankersOnline.com 12/15/03

First published on 12/15/2003

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Filed under technology as: 

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