We have a customer that is an avid online banking user. He has numerous EFT debits and credits on his account and has requested that we not send him a paper statement since he reviews his account online. Currently we do not have e-statements but it is on the project board.

My question is Reg E requires me to provide him with a statement because of the drafts, safety and security isssues require me to issue him a statement due to counterfeits/forgeries, etc. If all account holders sign written authorization to not send a paper statement, can/should I allow this?

No. Unless you are e-statement capable and you enroll customers in an e-statement program in compliance with the E-SIGN Act, you must make a paper statement available under Regulation E. The customer cannot waive the requirement.

Some customers have signed "hold statement" orders, but these are risky, too.

Tell the customer he's under no requirement to open the statement, although the bank often includes important information and alerts in or with bank statements. But he'll have to continue getting paper statements until the bank is ready to provide statements electronically.

We have several "hold statement" orders here and are considering eliminating this practice. How would you suggest a practical way about doing so? Ours is a little wider as it is caleld a "No Mail Request" (privacy and 1099 are mailed regardless if they are not picked up by a certain date). Suggestions?

I would provide letter to each customer advising that effective a certain date the service will no longer be provided. I would be sure to allow sufficient time to enable customers to obtain PO boxes if needed. You might also remind customers to notify bank promptly if a mailing address changes.

Yes, but we have an agreement "not to mail them anything"...and these are much older accounts where we do not have current phone numbers, and we do not often see these customers in the branch, hence the dilemma.

Mail them the notice that this service is being discontinued to their last known address. Any that are returned, then deal with those few as best you can. Just because there is a current agreement doesn't mean it can never be modified.