VIA E-MAIL: email@example.com
April 2, 2001
Office of the Chief Counsel
National Telecommunications and Information Administration
Room 4713 HCHB
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Re: Notice and Request for Comment on Section 105(a) of the
Electronic Signatures in Global and National Commerce Act
Dear Ms. Scarlett:
Thank you for the opportunity to comment pursuant to § 105(a) of the Electronic Signatures in Global and National Commerce Act (“E-sign”) on the effectiveness of delivery of electronic records to consumers using electronic mail as compared with the delivery of written records via the United States Postal Service and private express mail services. Household Bank (Nevada), N.A., Household Bank (SB), N.A., and Household Credit Services, Inc. (collectively “Household”), respectfully provide the following comments. Household is a leading provider of consumer credit card products in the United States. In connection with the provision of these products, Household mails approximately 230 million statements and letters annually via first class mail. With respect to several of its products, Household either provides or is considering providing written records through electronic means. E-sign allows a business to provide or make available to consumers account information via electronic means, provided that the consumer affirmatively consents to such transmission. Household acknowledges the value of statutes like E-sign that facilitate the use and growth of electronic commerce.
The dramatic growth in the use of the internet as a means to access financial products and services makes it feasible for information to be provided to consumers in what is often a more cost-efficient and consumer-friendly fashion than the traditional paper-based format. Household is beginning to provide electronic delivery as an option for several of its products. For example, Household currently operates websites that allow a consumer to consent to receipt of electronic account statement information while still receiving postal service delivery of account statements. On these sites, when a consumer enrolls in an “account access” program, Household obtains an affirmative answer from the consumer regarding the consumer’s computer capability and the consumer’s desire to receive electronic information regarding their account. Once we receive the consumer’s consent to receipt of electronic communications by affirmative response, the consumer may then choose other electronic communication options such as being notified when a payment is due or when their account balance is nearing their credit limit. Providing consumers the ability to receive account information by electronic transmission means that the consumers receive such information almost instantaneously. Moreover, the information available to the consumer is current as of the time the consumer accesses the website.
The potential for cost savings resulting from such electronic access is significant. Household spends roughly $73 million on postage each year to mail consumer statements via the postal service. In the future, our customers will be able to choose to receive account information solely by electronic transmission. If the paper statement need not be mailed, providing customers with electronic access to account statements results in a cost savings of approximately 39 cents per statement.
On many levels, electronic transmission of customer information provides substantial benefits to both consumers and financial services providers. Thus, we support initiatives like E-sign that help make such transmission feasible and appreciate the opportunity to provide these comments.
Associate General Counsel
Federal Regulatory Coordination