We currently have 3 ACH originations for loan payments being pulled monthly from other financial institutions. They post to our customer's loan record as regular payments with ACH reference and information.

At this point, I have been mailing a monthly statement to our customer because this is an EFT item.

I was told that the periodic (monthly) statement were only applicable to demand accounts and not loan accounts.

I am not seeing anything in the regulation which would be specific enough to say that we do not have to send a statement on a loan account.

Please advise.

Sec. 205.2 Definitions.

For purposes of this part, the following definitions apply:

(b)(1) Account means a demand deposit (checking), savings, or other consumer asset account (other than an occasional or incidental credit balance in a credit plan) held directly or indirectly by a financial institution and established primarily for personal, family, or household purposes.
(2)The term includes a "payroll card account" which is an account that is directly or indirectly established through an employer and to which electronic fund transfers of the consumer's wages, salary, or other employee compensation (such as commissions), are made on a recurring basis, whether the account is operated or managed by the employer, a third-party payroll processor, a depository institution or any other person. For rules governing payroll card accounts, see § 205.18.
(3) The term does not include an account held by a financial institution under a bona fide trust agreement.