Electronic Statement Service: Compliance with E-Sign Act
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YourMSR.com's E-Statement Service ensures credit unions adhere to the E-Sign Act by providing electronic disclosures and online statement options. The Act requires proper consent and disclosure location guidelines to be followed. NCUA regulations are also considered for compliance.
Electronic Statement Service: Compliance with E-Sign Act
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Presentation Transcript
Electronic Signature in Global& National Commerce (E-Sign) Act • The E-Sign Act allows credit unions to provide disclosures in an electronic format rather than a written form. • YourMSR.com may provide its client credit unions with the option of posting their members’ statements online instead of mailing them.
Consent The E-Sign Act states that customers must be provided with the following information before they can consent to receiving their statements online: • Any right or option to receive a disclosure in paper form; • Whether the consent applies only to a particular transaction or to other categories;
Consent Cont’d • The right to withdraw consent and how to do so; • How the member may obtain a paper copy upon request; and • Hardware and software requirements.
Location of Disclosure • The credit union may either send the disclosure to the member’s electronic address or make it available at the credit union’s Internet website. • YourMSR.com proposes to offer customers’ statements on the credit union’s website.
NCUA Reg. 707.10(d)(2) • If posting the statement online, this regulation requires: • Alert the member of the disclosure’s availability by sending a notice to the member’s electronic address (or postal address, at the credit union’s option). • Make the disclosure available for at least 90 days.
Other NCUA Regulations • NCUA Reg. 707.10(e) deals with disclosures that are bounced back to the credit union undelivered. • This regulation is not relevant because YourMSR.com will not be sending statements through email. • YourMSR.com’s e-messaging system.