Hi All,

If my understanding's correct, the Federal Reserve Board has just issued
some proposals for comment that would make electronic communication a legal
delivery mechanism for certain financial information.  I know that more and
more banks are doing online and other alternative format deliveries but
this might still be appropriate for interested individuals and consumer
organizations to comment in support of electronic delivery of information.
Personally I think it is a good idea to get electronic delivery of
information into law.

It would also seem that this might be an opportunity to continue to
advocate for accessibility in the entire financial paperwork process.  As
an example, this press release makes it clear that informed consent
documents during say a mortgage closing must still be on paper and in print.

Below is a copy of the press release.  The web page has links to supporting
documents.  These materials are in the Adobe PDF file format but do seem to
convert reasonably well with the various conversion options.

The URLs to the two PDF files are:

http://www.bog.frb.fed.us/BoardDocs/Meetings/1999/19990818/081899OpenMemoPt1
.pdf

http://www.bog.frb.fed.us/BoardDocs/Meetings/1999/19990818/081899OpenMemoPt2
.pdf

From the web page:

http://www.bog.frb.fed.us/BoardDocs/Press/BoardActs/1999/19990818/DEFAULT.HTM


Release Date: August 18, 1999


For immediate release


The Federal Reserve Board today voted to issue for comment proposals that
would permit financial institutions and others to use electronic
communication to provide federally mandated disclosures to consumers.
Comments must be received by October 29, 1999.

The proposals would authorize the electronic delivery of disclosures
required to be given in writing under Regulations B (Equal Credit
Opportunity), E (Electronic Fund Transfers), M (Consumer Leasing), Z (Truth
in Lending) and DD (Truth in Savings).

With some exceptions, prior to obtaining the consumer's consent, financial
institutions and others would have to provide --through a standardized
disclosure statement--specific information about electronic disclosures,
including what type of disclosures would be provided electronically, and
how the consumer can receive and retain the disclosures.

The Board also voted to issue for comment an interim rule for Regulation DD
that would permit depository institutions to provide disclosures
electronically on periodic statements of account activity.

Electronic disclosures could be delivered to a consumer's e-mail address or
made available at another location such as an institution's web site. If an
institution opts to make disclosures available at a web site, it must send
a notice alerting a consumer when the information has been posted.

Today's proposal represents a modification of proposed rules (and an
interim rule under Regulation E) issued in March 1998. In response to
comments, the modified proposals are more detailed than the 1998 proposals
and provide more specific guidance to institutions that choose electronic
communication.

The modified proposal generally would require disclosures be made on paper
when a consumer is transacting business in person, as is typical for
mortgage loan closings, automobile loans and leases and door-to-door credit
sales.

Some disclosures that are generally available to the public, such as bank
account fee schedules, could be made available electronically without the
consumer's consent.

All other disclosures could be delivered electronically, if the institution
provides the disclosure statement about electronic delivery and obtains
both the consumer's affirmative consent and the consumer's confirmation
that the consumer's computer equipment meets the technical requirements
necessary to receive and retain electronic disclosures.


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