We are in the process of starting e-statements for our customers. They will have to sign into our secure internet banking site to view their statements. However, the statements will be coming from another imaging company that does our imaging processing. These two companies are forming a single sign in for the images. I keep hearing about "demonstrable consent"; would we still have to prove this with our customers signing into a site that they have been or does this rule apply because it is the customers' actual statements being viewed?
Our bank is soon going to provide customers with the option to receive electronic statements. When they sign up for this feature, we are required to provide a disclosure. What do I need to include on that disclosure to comply with all the regulations?
We have a form available for customers to sign, who have access to Internet banking and online statements, if they wish to discontinue receiving paper statements in the mail. Is it necessary to have signatures of all signers, if it is a joint account? Can one account owner opt out of paper statements for a joint account?
Can we send the Overdraft Fee Notice in our monthly statements, and can we only send the notice to our existing customers with debit/ATM cards?
Can someone tell me if there is a requirement to deliver the error resolution jointly with the statement? We are in the process of rolling out e-statements, but due to system limitations, our customers will only be able to view their statement information pulled from our system, and not the error resolution (currently preprinted on the back of the paper statement). We plan to have an error resolution link "in case of errors, please click here" on the page that leads them to their statement. Are we OK on this?
We recently acquired two banks from the FDIC. One of them has e-statements, as do we. Do they have to agree to our e-statement terms or does the agreement with their current bank still apply?
Please explain "simple customer agreement" regarding electronic consent for the ATM/1-time debit transaction opt-in?
We currently have e-statements available for our e-banking customers and will be adding e-bills. Any e-banking customers that have e-statement and a loan account within their profile, will be converted to an e-bill for these loans. We will continue to send both the e-bill and the paper bill for a two to three month time period. There is no way to have these customers agree or accept a revised agreement without shutting off all e-statements and have them agree again, which is not a good option from a customer service perspective. Will we be OK if we send an email communication to all e-banking customers of the pending change and have a message printed on the loan bills alerting customers to the pending change? e-statement customers agreed to receive all disclosures and statements electronically when they initially signed up for e-statements.
Management is searching for a way to use the internet sign-in process by customers (two factor authentication) as "demonstrable consent" for purposes of E-Sign. I am seeking support for why multi-factor alone cannot be used as demonstrable consent, verifying that the customer was able to receive and read materials sent to them.
Our signature card currently states, "The undersigned also acknowledge the receipt of a copy and agree to the terms of the following disclosure(s): Funds Availability, Truth in Savings, EFT, and Privacy." For certain products we require e-statements. We are considering modifying the signature card to include "e-statement agreement" as part of the list of disclosures they agree to and not require the customer to sign a separate e-statement agreement. Do you see any concerns with this?