Preauthorized transfers to accounts include SSA or VA benefits payments, payroll direct deposit, etc. Those sorts of EFTs don't need to trigger a statement requriement for a passbook account.
However, if the customer has personal EFT access - an ATM card or debit card, for example, that exception disappears.
The fact that the customer can make an in-person withdrawal with the passbook doesn't kill the exception; the fact that other types of EFTs (ACH debits, ATM or debit card transactions, for example) are allowed to hit the account would eliminate the exception.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8