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I’m looking for resources to help me understand what is required when we add access by mobile phone to our on-line banking platform. Has anyone else had experience with this or know what examiners expect to see? Our customers receive the ESIGN consent and Reg E disclosures when they sign up for on-line banking – but if they then register their mobile device for access, will they have to get these same disclosures again?
If you’re providing disclosures through the mobile app then e-sign would come into play. And your Reg E disclosure may need to be revised and re-disclosed. The article below offers some insight on these topics. https://www.aba.com/Products/bankcompliance/Documents/SeptOct12CoverStory.pdf
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