We are in the process of adding external account transfer capability (A2A)to our Internet banking service. Our vendor indicates that these transactions will show on our statements as Internet-initiated transactions and all transactions will display our own bank name. It is my contention that the statement should indicate the name of the other institution and I believe Reg E 205.9 (b)(1)(v) supports this. Of course, since it would only be logical to have the name of the other F.I. on the statement, it probably isn't required.
We had a customer ask us to replace a damaged card. She never received or reported that she didn't receive her replacement card. In the mean time, the new and old card are being used. Three months pass before she discovers and reports to the bank that she did not get her replacement card. Is she liable since she did not report this to the bank? She knew she asked for a replacement card; knew she didn't get it, and never contacted us.
We currently print the error resolution notice on the back of our E-banking paper statement. We are going to start sending electronic statements. The error resolution notice will not be included in the electronic statement. If we provide a link within the email to a page with the error resolution notice on our bank’s webpage will it suffice?
When we provide electronic statements are we required to provide an account balancing form as well?
We are switching from html e-statements to a pdf format. Do we need our customers' to consent change to the new pdf format?
We are looking for some clarification on Reg E - 205.9 on periodic statements. In section (a) it talks about what is required on the receipt from a merchant, then in (b) when it is talking about the periodic statements, the requirement (v) says the name of any third party to or from whom funds were transferred. We have several merchants in the area that are passing just an address in the field captured by the core product and not putting an actual name. Is the merchant, such as ABC Company, considered the third party, and is the company name required on the statement? The item appears with date, amount, terminal ID number, location, but does not necessarily say the business name.
Our bank is currently in the process of testing electronic delivery of monthly deposit account statements to employees on a voluntary basis. The statements are delivered in the following manner: an e-mail notification is sent to customers letting them know that the statement is available for review. Then, in order to view the statement, the customer is required to sign onto the bank's website, where the statement can then be accessed (in order to receive electronic statements, the customer must be signed up for e-banking). The statement can then be printed and/or saved to another file by the customer. What would be the E-SIGN ramifications, if any, of this type of statement delivery? Does this type of statement delivery require the bank to obtain demonstrable consent? Would the log on procedures (username and password) suffice for the customer's electronic signature, etc.?
If we were to offer our credit card customers access to their accounts online, and they can view their monthly statements, are we required to also send them a paper statement?
Is there a requirement for an e-statement to be a mirror image of the printed statement as it relates to formatting and marketing messages?
Can someone please explain what “push” and “pull” mean in regards to e-banking?