Requirements for "Opt In" Online Statements

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Question:

If a customer "opts in" to have their statements provided in their online banking, are we obligated or regulated to send them a paper statement AND online statement the 1st month their statement cycles?

Answer:

No. After you and the customer have gone through the ESIGN opt-in process, your e-documents are viewed by federal laws as "in writing." I'm not aware of any dual delivery requirements, but several banking regulations may apply to your statements (depending on content.) To be sure where you stand, you'd be wise to determine which regs apply and review these regs for dual delivery requirements.

First published on BankersOnline.com 7/25/11