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#1865769 - 10/28/13 04:49 PM Mobile App Reg E Disclosures
ComplianceGrl15 Offline
Gold Star

Registered: 04/18/11
Posts: 254
We are about ready to roll out a new mobile app.

Are we required to provide a new Reg E disclosure that includes the mobile app service to every consumer or just those that sign up for the new mobile app?

Thanks.

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eBanking / Technology
#1865801 - 10/28/13 07:11 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
GuitarDude Offline
Power Poster

Registered: 11/17/04
Posts: 5635
Loc: So Cal
You would just need to provide the disclosure to consumers who request the new service, before they perform an EFT through the mobile app.
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I've just writed a wrong.

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#1869827 - 11/08/13 01:16 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
Bank Compliance Offline
New Poster

Registered: 04/21/09
Posts: 16
Would a Reg E disclousre be necessary for mobile banking app if prior to getting mobile banking the customer has to be enrolled in online banking and online bill pay. The customer cannot do anything new on the app they can only do the things they can do in online banking and they can only pay bills that have been previously set up on bill pay (they cannot set up new payees) and there are no new fees or changes in fees.

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#1869831 - 11/08/13 01:22 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49725
Loc: Galveston, TX
Sounds like a new access device to me unless all they are doing is accessing the current online banking site via a mobile device.
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The opinions expressed are my own, take them or leave them.

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#1869843 - 11/08/13 01:39 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
Bank Compliance Offline
New Poster

Registered: 04/21/09
Posts: 16
That is what I am trying to determine- it isn't anything new- it is just through our mobile app that they will be accessing it... Customers have to use their online banking user name/password to access their informaiton on the mobile app.

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#1905544 - 03/14/14 12:45 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 904
Please correct me if I'm wrong but the way I interpret this is if customers are accessing the current online banking site via a mobile device disclosures should be updated but there is no need to re-disclose to existing customers.

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#1905553 - 03/14/14 01:06 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 904
For clarification purposes, currently we do not disclose mobile banking in our Reg E disclosures since we consider it part of online banking which is currently disclosed. We considered mobile banking part of online banking since that is what the customer will access via their mobile device.

Since we are now going to distinguish online banking and mobile banking separately in our Reg E disclosures are we required to re-disclose to our existing customers?

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#1905596 - 03/14/14 02:09 PM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49725
Loc: Galveston, TX
Well, it is either a separate access device or it is not. If it is, you have to disclose it as such. If it is not, why go through this exercise?
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The opinions expressed are my own, take them or leave them.

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#1905813 - 03/17/14 09:43 AM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 904
Sorry but I'm still not sure what we are required to do.

I consider this a new device but not a new service since the customer will access via their mobile device and the mobile banking application is a part of our existing online banking.

We will disclose to distinguish the access devices. Once the disclosures are updated are we required to re-disclose to our existing customers?

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#1905820 - 03/17/14 09:55 AM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49725
Loc: Galveston, TX
If you determine it to be a separate access device, then yes, you would have to provide a disclosure to all customers that have that access device available.

Although if you are using the same password and PIN and the only difference is a mobile platform versus a desktop platform and all services they access are the same, I'm not sure why it would be a separate access device.
_________________________
The opinions expressed are my own, take them or leave them.

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#1905870 - 03/17/14 11:00 AM Re: Mobile App Reg E Disclosures [Re: ComplianceGrl15]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 904
OK, now I got it.

Thanks for the clarification.

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