Delivering Account Opening Disclosures Electronically
Can a credit union deliver account opening disclosures electronically? You’d think this would be a pretty simple, cut and dry question and answer. Unfortunately, it’s not as quick as we’d like. This is a really great example of how regulations don’t keep pace with changing technology. What made sense when the rules were written, no longer seem to make a whole lot of sense today with our ability to provide instant access to information electronically
When we consider opening new deposit accounts, typically a credit union must provide disclosures for Truth in Savings (12 CFR 707.3 and 4), Regulation E (12 CFR 1005.7), Regulation CC (12 CFR 229.17), and Privacy (12 CFR 716.4) before the account may be opened or before a transaction occurs (in the case of Regulation E). The disclosures must be in writing and in a form the consumer may keep. For the most part, disclosures may be sent electronically, if the consumer agrees AND all the E-Sign requirements are met. It’s the E-Sign requirements that tend to trip credit unions up.
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