Consumers Should Have the Unfettered Choice of Paper or Electronic Statements
A recent paper published by the National Consumer Law Centre titled Paper Statements: An Important Consumer Protection provides some important guidelines to financial institutions that are implementing e-migration strategies. The publication, referencing US legal and compliance guidelines, urges the careful consideration of many consumer choice considerations and ultimately lands on a theme that we strongly support – CONSUMERS SHOULD HAVE THE UNFETTERED CHOICE OF PAPER OR ELECTRONIC STATEMENTS.
Some of their findings may surprise readers. The Digital Divide which is defined as the number of households that do not have access to broadband internet (to access e-statements) has actually grown by 3% for certain demographic groups in the United States. They also make a case that printed statements are more likely to be read than an e-statement. But their overwhelming recommendation is that converting customers from print statements to e-statements should be done with care and fully respecting customer consent. The Electronic Signatures in Global and National Commerce Act (E-Sign) Act requires that Financial Institutions comply with 4 key guidelines;
1. The consumer must affirmatively consent to electronic delivery.
2. The financial institution must make certain disclosures to the consumer.
3. The consumer’s consent must demonstrate that he or she has access to the equipment and programs necessary to receive, open, and read the relevant electronic documents.
4. The consumer must be given notice of the right to withdraw consent for electronic delivery.
We are actively working with our clients implementing e-migration programs. The current state of e-delivery for many Financial Institutions in Canada is very low and there is an opportunity to both improve customer satisfaction, reduce costs and be a better environmental steward….the triple bottom line. While pursuing these very appealing goals, we believe it is important to respect consumer choice and this paper does an excellent job of supporting this approach.