Is it a problem if our Internet Banking System tracks a users E-Consent to enroll an account in E-Statements and allows the user to enroll in subsequent accounts by checking a box without forcing them through the E-Consent disclosure process?

The initial E-Consent disclosure process does present the disclosure in a form the statements would be delivered in and they agree within that form in order to "prove" they can access it. The disclosure includes all the required information and states, "By enrolling, you agree to receive your statements electronically (via email). Upon enrolling, you will no longer receive statements in the mail for the accounts you have selected.... You have chosen to receive the following information electronically: periodic statements, Overdraft Notices, Bounce Protection Notices, Charge Back Notices, Outgoing Wire Notices, Incoming Wire Notices, Loan Billing Notices, First Past Due Notices, Second Past Due Notices, Dormant Account Notices, Tax Statements, and updates to bank disclosures."

Any time the E-Consent Disclosure changes, it is represented the the users the next time they log in to their internet banking and they are forced to choose to agree/consent or not consent before proceeding.

If it is all ok to let them enroll future accounts in e-statements with the check of a box and not stepping through E-Consent again... My next concern is if the user un-enrolls ALL their accounts from E-Statements (essentially withdrawing ALL their consent), the system still remembers that the user agreed to the current E-Consent Disclosure at one time (assuming the disclosure hasn't changed since their agreement) and lets them re-enroll the accounts in E-Statements without forcing them back through the E-Consent Disclosure process. Is that ok??