Banks need to be more alert to possible compliance and transaction risks when they replace their paper-based consumer notices or disclosures with electronic disclosures, the Office of the Comptroller of the Currency warned in an advisory letter concerning the E-SIGN Act. The statute requires that before consumers can consent to receiving electronic notices about their transactions, they must receive certain “clear and conspicuous” disclosures. These pre-consent disclosures include information on any right or option to…