For an internal transfer (checking or savings to loan), is it required by a regulation to have a customer sign an automatic payment set up form? We require an ACH authorization form to be completed for all external automatic payment set ups (external checking or savings to loan), but were unsure if this requirement is the same for internal transfers. Thanks

if you will be setting this up permanently, I would say you would need an authorization on file. Otherwise, how do you know how to set it up? Customer making the request via your internet banking platform should also have a record maintained.

Regulation E does not cover these transfers, except to prohibit a requirement that e-transfers be used to pay the loan. So Reg. E does not require a written authorization for these types of transactions.

By e-transfers, do you mean an online electronic transfer initated by the cusomter or the bank (or both)??

The transfers inquired about in the initial question are recurring automated transfers authorized by the borrower, but each transfer is initiated by the lending bank.