WASHINGTON (5/31/12)--Combined remittance notices that are provided electronically to credit union members and others that request remittance transfers online will be required to comply with the Electronic Signatures in Global and National Commerce (ESIGN) Act, Credit Union National Association (CUNA) Director of Compliance Information Valerie Moss said in a recent Comp Blog post.
These requirements fall under the Consumer Financial Protection Bureau's Regulation E remittance rule, which goes into effect on Feb. 7, 2013.
ESIGN imposes special requirements on businesses that use electronic records or signatures in consumer transactions, and requires certain disclosures to be provided to consumers before an electronic document can be "signed" online or an electronic transaction can be completed.
Moss in the blog post noted that when a sender electronically requests a remittance transfer, the financial institution that is originating the remittance transfer may provide the pre-payment notice to the sender in electronic form without regard to ESIGN's consumer consent provisions. The receipt may also be provided in electronic form, but must comply with ESIGN.
In the case of a combined notice, Moss said, ESIGN applies since half of the disclosure would fall under those requirements.
For more of CUNA's Comp Blog, use the resource link.