We implemented the push method.. We send our customers an email telling them that the statement is ready for review.
My question is do we have to tell them specific instructions on how to view it?

First, what you indicated is "pull"; you pull them into your site for their statement/info. Or you "push" the statement/info out to them.

For statements, look to 205.17. "The notice shall identify the account involved and the address of the Internet web site or other location where the disclosure is available..."

Yes, I am sorry. I meant to say "pull."
By saying "account involved," do we have to state the account number??
Thanks.

No. The OSC makes this clear. And if the message is not encrypted it may be best to stay away from using the account number, at least using all of it. You may truncate the number, use the names, etc.

Aren't you requiring these customers to take a test drive before signing them up for e-delivery? If they passed the test drive, what other instructions would they need?

We have included simple instructions along with a link to our website on the email the customer gets - most customers won't need them but we figured that this would be easier than answering calls from customers on a monthly basis.

Andy,

We are about to roll out e-statements and I want to make sure I understand your response. You are advising not to list all or any of the account number. This is in reference to the email notice only, correct? I am criticizing our program because when the customer pulls his or her statement, they have @xxxxxxx@ in the account number location ON THE STATEMENT. For Reg. E compliance, I can't see any way around not putting the account number on the statement that is actually to be retrieved from the system.

The message announcing the availability of the statement is required to identify the account involved. That description need not include the account number if you can sufficiently describe it with "checking account" or "savings account" or some other descriptor. From the Commentary to Regulation DD, section 230.10:

Identifying account involved. A depository institution may identify a specific account in a variety of ways and is not required to identify an account by reference to the account number. For example, where the consumer has only one deposit account, and no confusion would result, the depository institution may refer to “your deposit account.” If the consumer has two accounts, the depository institution may, for example, differentiate accounts by using terms such as “primary account” and “secondary account” or by using a truncated account number.

I presume that the customer's statement will reside on a secure server, and require password verification for access. If that is the case, what harm is there in including the account number on the statement, if you'd do so on a statement that you send by mail?

John,
I agree with your statements and believe we should have the account number on the statement. But in my first test, the statement didn't show the account number. My point to management will be that they are not complying with Regulation E, 205.9(b)(2).

Your assumption is correct, the statement will reside on a secure server and the customer can't get to it without entering the login ID and password.

I want to use this thread as additional support, but before I do, I would like to verify that Andy's response was only addressing the notice, not the statement.

I can confirm that Andy's response only concerned the notice. He knows Reg. E as well as I do (or better), and knows that it requires that the account number be included on the statement.

Thanks once again John.

Yes, I was discussing the notice. In my case, an older practice, now discontinued, was to list the account number, in its entirety in the email subject line. That is not the best practice.