Are banks required to disclose an 800 number in Reg E? We have always had an 800 number but they just canceled it.
Does an additional regulation e disclosure have to be given to a member every time a new electronic service or device is added?
For online banking, is it acceptable to have the EFT and eSign disclosures open as one document (both displayed on the screen in full) and then assent to both with ONE click?
When a bank restricts the use of a customer's access device due to excessive transactions under Reg D, does it have to send the Reg E 21-day change in terms notice?
We are getting really to roll out eStatements. Where do I find information on who is required to sign an Opt In/Opt out agreement (Business or Personal Accounts)? When must the statement be available to view online? etc etc.
In regards to the final rule on the amendment to Reg E - Foreign Remittance Transfers, I am wondering how you interpret the official staff commentary on how to determine the number of remittance transfers provided in order to fall under the remittance transfer provider safe harbor of sending 100 or less remittance transfers in a year (1005.30(f)(2)(ii)). More specifically, do remittance transfers requested by business senders count in the 100 transfers? For example, if our bank sends 140 total remittance transfers per year, but only 80 of the transfers are requested by consumer senders (the other 60 were requested by business senders), does our bank only have 80 qualifying remittance transfers, thereby qualifying us for the safe harbor in which we would not have to adhere to the disclosure requirements of this rule?
We are adding ebills to our edocument service. If a customer chooses to receive an e-bill for their mortgage, all other accounts will be converted to e-statements as well. Is this considered a violation of the ESIGN Act as the customer is only signing up for the mortgage bill?
The agreement we have customers sign when they enroll in our online banking product includes language regarding the Bill Pay feature. If a customer chooses not to use Bill Pay at that time but decides to take advantage of it at a later date, would they need to sign an additional document or disclosure? If it is not a requirement, would it be a best practice to have them sign something or provide them with a complimentary document that describes the Bill Pay features? Any help along with possible regulatory cites is very much appreciated.
A Q and A dated 10/26/09 by Richard Insley "E-Statement Agreement" states the following,"Although you are free to require e-statements as a condition of a new product, you can not require existing product-holders to relinquish paper statements and accept e-delivery." What regulation does this statement come from?
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?