07/06/2009
We would like to set up an online banking chat on our bank’s website, where our online banking customers will able to contact a customer service representative regarding their accounts. What compliance issues do we need to address to implement this service?
06/01/2009
Our bank is currently in the process of testing electronic delivery of monthly deposit account statements to employees on a voluntary basis. The statements are delivered in the following manner: an e-mail notification is sent to customers letting them know that the statement is available for review. Then, in order to view the statement, the customer is required to sign onto the bank's website, where the statement can then be accessed (in order to receive electronic statements, the customer must be signed up for e-banking). The statement can then be printed and/or saved to another file by the customer. What would be the E-SIGN ramifications, if any, of this type of statement delivery? Does this type of statement delivery require the bank to obtain demonstrable consent? Would the log on procedures (username and password) suffice for the customer's electronic signature, etc.?
05/11/2009
If a borrower calls and wants a mortgage home loan, under the E-sign rules, could the Loan Officer e-mail the regulatory disclosures, Authorization certification, RESPA Servicing, Private Policy, and GFE/TIL to the consumer without first making the LO send an e-mail to the borrower for an electronic consent and have the borrower send it back?
05/04/2009
If we were to offer our credit card customers access to their accounts online, and they can view their monthly statements, are we required to also send them a paper statement?
04/06/2009
We want to offer loan and deposit products online. What disclosure differences will we have to make?
04/06/2009
We want to make mortgage loan applications available on our internet banking website. What are some of the issues we need to prepare for?
03/23/2009
Can someone please explain what “push” and “pull” mean in regards to e-banking?
03/02/2009
Are there specific disclosures and daily withdrawal limits associated with a business debit/check card?
02/23/2009
The E-SIGN Act authorized institutions to provide electronic disclosures if prior customer consent is properly obtained. There is some discussion that amendments were made to Regs E and DD to withdraw portions of the rules on electronic disclosures. Is prior consent to receive notices electronically required if consumers receive internet banking disclosures via an electronic channel as part of their online registration process for internet banking and/or bill payment services?
01/19/2009
We have e-banking customers who do not want to get a paper or email statement because they view their account history online. Are we out of compliance if we stop sending email or printed statements?