04/21/2008
If we have customers download and print a loan application that is mailed back in, do rules concerning electronic delivery apply here?
04/14/2008
I read on BOL that our web site disclosures need to be "clear and conspicuous" like on paper. But how is this defined when the user has some control over the way our pages are displayed?
04/14/2008
How can we ensure a customer receiving e-statements actually can retain them, as we are required to ask?
04/07/2008
Do we have to prove that our customer can receive their statement electronically even though they verbally acknowledge that they can receive their statement and view it based on the computer requirements we outlined in the agreement? For example, should we send an email to the customer to confirm that their email address is valid to receive the notification when the statement is ready?
03/31/2008
We typically provide our Reg DD change of terms notices via statement message. Our customers that receive e-statements have consented to receive the statement electronically and we send them an e-mail advising them the statement is available. Is this sufficient to cover change of terms requirements or are we required to specifically advise them that a change of terms notice is included with the statement?
03/31/2008
Must the E-Sign disclosures and opt-in be delivered electronically(such as by viewing and accepting on a webpage) or can it also be disclosed and accepted using a paper document?
03/17/2008
Are we required to send paper statements at the end of the year to members who are signed up for e-statements?
03/10/2008
We are starting a business debit card program. While working on our disclosures we have come across something we're not sure how to address: business customers who request to have personal accounts linked to their business debit cards. Is this a permissible practice, and what are some liabilities facing us in such a situation?
03/03/2008
When would it be necessary to include a speed bump on a bank web site when moving from the bank web page to other pages such as mortgage or investment affiliates?
02/25/2008
What is the longest amount of time we can take before giving the customer final credit or declining their request with fraudulent transactions on a debit card after provisional credit has been given?