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#1115182 - 01/22/09 05:48 PM Quick Reg E Disclosure Question
BankerBobby Offline
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BankerBobby
Joined: Jan 2004
Posts: 132
If the Bank obtains a signed authorization from its new loan customer to debit their deposit account at another institution monthly for their loan payments, what disclosures are required other than the signed authorization?

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eBanking / Technology
#1115496 - 01/22/09 08:58 PM Re: Quick Reg E Disclosure Question BankerBobby
BankerBobby Offline
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BankerBobby
Joined: Jan 2004
Posts: 132
More specifically, would our standard Reg. E Disclosure need to be provided to the customer with the signed authorization form?

Would there be any notifications or disclosures upon debiting of their account? or crediting of their loan?

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#1117924 - 01/28/09 03:16 PM Re: Quick Reg E Disclosure Question BankerBobby
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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