I've not seen this question before, but would initially identify the account's purpose - personal, family or household use, a consumer account. I believe this criteria would be met and the account could be Reg E applicable. Though I'd wonder what transfers are coming out of the account. I've no experience on that side. But I'm open to opinions from those more familiar with the account type.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell