Do mobile banking functions such as peer-to-peer (IPay) types of payment need additional Reg E disclosures, or are they merely a function of Internet/bill pay banking do not need additional disclosures?

I'll venture a guess and hope someone else has additional thoughts. I think if the platform is outside the FI (such as iPay, Paypal, etc.) additional Reg E disclosures are not required but if it is the FI's platform (their own mobile banking app), it would be subject to disclosures. My thinking is that the FI providing the app constitutes issuance of a new "access device" whereas the use of iPay, Paypal, etc. is using an existing device (online banking access previously disclosed).