At the risk of sounding like a complete idiot, can anyone tell me when a bank would make a one-time electronic fund transfer using information from a check, where we would need to include the disclosures in Appendix A-6? As I read down section 205.3(c) (3), it excludes wires, which is all I can think of.

I am trying to figure out if we need to edit our disclosures. They are already confusing enough and four pages long, but I want us in compliance.

C'mon, if we never do this, then why are the regulators making us disclose it?

We are not doing this yet, but if the bank chose to convert loan payments received to ECCs, then the bank would have to disclose this to the customer (standard language on a monthly statement, or disclosure added to a coupon book.

If you're not doing this, you don't need the new A-6 disclosure. But some banks handle lockbox transfers and may. Credit card payments are common for this one-time transfer and I hear many mortgage servicers do as well.

Thanx! I didn't think we did anything like this, but wasn't sure if I was missing anything. Doing the deposit review always leaves my head spinning. (Reg CC, D, DD, E and Q all at once!)