Answer:
Regulation E allows an "access device" to be requested orally. There may be state laws that further restrict the issuance of cards and require a signature. From a practical perspective, your bank may want to have some way to authenticate the card request. A signature on a simple application is one method for authentication. A card request from a customer signed into your e-banking product might be another. Unless there is a state requirement, a written application (and therefore a signature) is not required.
First published on BankersOnline.com 9/03/07