The LOB is proposing a process whereby the amount of an incoming EFT debit could be split, allowing a portion of the transaction to come from the HSA deposit account, and in the case that there were insufficient funds to cover the entire amount, allow the remainder of the funds to come from a HSA line of credit.
I know HSA's aren't covered under Reg E, but we afford the same coverage to these accounts, provide the same disclosures, thus we feel we need to comply with Reg E.
My concern is that when the transaction amount posts to the deposit account, it wouldn't match the actual amount of the transaction and may not meet periodic statement requirements under Reg E. They proposed a solution of including the full transaction amount in the description of the item on the statement, but will this work and satisfy all aspects of Reg E?