Are there any regulations that govern ATM card issuing for rep payee accounts (SSI/SSA)?
Are there any regs that say a FI must deactivate an online/Internet banking login if they haven't logged in for a specific period?
If a customer "opts in" to have their statements provided in their online banking, are we obligated or regulated to send them a paper statement AND online statement the 1st month their statement cycles?
We are thinking about adding loan notices (i.e. pmt notices/past due notices/ maturity notices/ rate adjustments/ etc.) to our list of items that a customer can sign up to get electronically. We already do it for deposit products (stmts and such). I realize I need to consult the applicable lending regs, most of which I believe defer to the esign act and allow for electronic delivery, but I'm just wondering if I'm missing something. I guess I'm a little nervous about sending someone's past due notice electronically even if they have to elect to receive it and confirm that they can (call me cautious). Is there anything else I need to watch out for? I am happy to do my own research but if you know of any prohibitions or can point me to something I'm missing, I would appreciate it.
We are looking at implementing E-Statements for business and retail customers but our internet banking provider does not have a method in which to notify the customer that their periodic statement is ready for viewing each month. Is there a regulation that mandates the bank to notify the customer each month (or statement cycle) that the electronic statement is available for viewing?
Are there specific disclosures and daily withdrawal limits associated with a business debit/check card?
The E-SIGN Act authorized institutions to provide electronic disclosures if prior customer consent is properly obtained. There is some discussion that amendments were made to Regs E and DD to withdraw portions of the rules on electronic disclosures. Is prior consent to receive notices electronically required if consumers receive internet banking disclosures via an electronic channel as part of their online registration process for internet banking and/or bill payment services?
What do the regulations say about how long a client has to dispute an unauthorized item that was paid on their bank statement? We have a client that is claiming a forged check item after sixty days. The only thing that I could find was the Reg E rules regarding electronic items.
We are considering making e-statements available to our customers. What compliance issues do we need to be address?
We typically provide our Reg DD change of terms notices via statement message. Our customers that receive e-statements have consented to receive the statement electronically and we send them an e-mail advising them the statement is available. Is this sufficient to cover change of terms requirements or are we required to specifically advise them that a change of terms notice is included with the statement?