Electronic Delivery of Consumer Disclosures – New Rules Go Back to the Future
On April 20, 2007, the Federal Reserve Board (the “FRB”) issued a proposal to withdraw portions of five interim final rules that address the electronic delivery of required consumer disclosures. The regulations are: B (implementing the Equal Credit Opportunity Act), E (implementing the Electronic Funds Transfer Act), M (implementing the Consumer Leasing Act), Z (implementing the Truth in Lending Act) and DD (implementing the Truth in Savings Act).
The withdrawal means that those who have attempted to comply with the interim rules, and those who ignored them, can and should now focus their attention on the requirements of the federal Electronic Signatures in Global and National Commerce Act (“E-Sign”). This creates both benefits and new ambiguities for financial institutions.
Click here to read the entire story by K&L Gates partners Jonathan Jaffe and Holly Towle.