As for statement requirements as long as the last name/last four digits of donor account are on the recipients statement are we covered?
With commercial customers if we decide to allow online transfers between entities with different EIN but same ownership will the travel rule apply?
The Comment in the Official Staff Interpretations to Reg E says "
Consumer as third-party payee. If a consumer makes an electronic fund transfer to another consumer, the financial institution must identify the recipient by name (not just by an account number, for example)." Theoretically, you could require that the originating consumer identify the receiving party and repeat that identification in the statement description. As for the statement information for the receiving party, you'd have to name the sending party, probably based on your CIF information, and I would not recommend including any of the sender's account number information.
If either party to the transfer is not a consumer, I think you have to be able to retrieve the information required by the funds transmittal recordkeeping rule.