You are not responsible for making disclosures under section 205.7 for these borrowers -- their affected deposit accounts are not in your bank. What you are responsible for is the authorization and disclosure provisions in section 205.10(b) and, if the loan payments can vary in amount, in section 205.10(d). Your customer must get a copy of the signed authorization.
If you will be using the ACH for collecting those payments, you should ensure that your signed authorization complies with Section 2.1 of NACHA Operating Rules.
If the payment amounts are uniform, or if you comply with the "range of amounts" provision in 205.10(d), you are not required to provide a notice for each transfer.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8