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.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8