E-Notices for NSF and Overdraft Protection As Well As CD Maturity and Renewals

Question:

Are electronic notices permitted for NSF and overdraft protection communication as well as CD maturity and renewals? Customers signing up for e-statements would automatically get these via e-notice, with an e-mail being issued to advise the customer of the e-notice. The customer would then log on to view it.

Answer:

If the e-sign consent describes the notices (e.g., NSF, ODP, maturity/renewal) you intend to send electronically, you are allowed to rely on the e-statement consent for this means of delivery. Otherwise, you would need to get the consumer's prior consent and follow the e-sign rules accordingly for these additional/new items to be sent electronically. Also, be sure to have a process in place to ensure consumers who withdraw their consent for e-statements/e-notices receive the paper format of the applicable notice.

Vendor:

Wipfli