My bank is looking at introducing a new product whereby an employee's payroll check is deposited into an deposit account, but immediately tranfered into several other accounts either by a specified $ amount or percentage. The proposal was that the intial account would essentially be invisible to the consumer and the statements would be generated for the resulting accounts. Since the initial "from" would be the consumer's employer, I do not think that the Reg. E exceptions found in 205.3 would apply and therefor a periodic statement would need to be generated for the initial pass through account. Does anyone have any additional thoughts on this topic? Thank you.

I'm confused but always wanting to learn/understand. Can you please tell me what the rationale is behind this proposed setup? Why make a deposit initially into a "pass through" account... what is the benefit?