We've seen several instances where consumer online banking credentials were fraudulently acquired (allegedly through consumer negligence/gullibility). In turn, "unauthorized" mobile deposits are hitting the account as are bill pays, P2Ps, etc to 3rd parties.

Because these mobile deposits credits and debits via OLB are all initiated via a computer/electronic terminal (which 1005.3(b)(1) considers an Electronic Fund Transfer), they all fall under Reg E's Error Resolution Procedures, right? Or do they? Is there a line, anywhere????

I am of the position they do fall under Reg E, but understandably I'm being urged to do some additional research. Hoping my gut is wrong!

I've done a bit more research and I'm seeing that Mobile Check Deposits, so long as their posted via RDC, are not protected under Reg E. Also, Bill Pay is protected under Reg E if the payments are deducted as ACHs, or the agreement explicitly states that some payee payments may be made via paper checks and those payees are identified to the consumer. All other transactions debit as ACHs and those are covered under Reg E.
Any one - feel free to add in your knowledge - we've been seeing more and more OLB fraud.