If the customer can use their credit card at an ATM or as a POS or telephone bill payment, does the use fall under the Electronic Fund Transfers?
I say no. The term EFT generally refers to a transaction initiated through an electronic terminal, telephone, computer, or magnetic tape that instructs a FI either to credit or to debit a consumer's asset account.
Credit cards are not an asset account. “Account†means a demand deposit (checking), savings, or other consumer asset account (other than an occasional or incidental credit balance in a credit plan) held directly or indirectly by a financial institution and established primarily for personal, family, or household purposes.
But the section that talks about unsolicited issuance of cards lists credit cards.