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.

You would just need to provide the disclosure to consumers who request the new service, before they perform an EFT through the mobile app.

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.

Sounds like a new access device to me unless all they are doing is accessing the current online banking site via a mobile device.

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.

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.

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?

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?

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?

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.

OK, now I got it.

Thanks for the clarification.