We offer a unique product. To simplify, there are four parties involved 1) a consumer 2) a company offering a service 3) the bank 4) a gov't agency

Comapny offers a service. Customer can choose to have the transaction settle from business with the company through the bank. We basically get an ACH in for the customer from the government and then turn around and either ACH them money back to the customer or cut them a check. We never open an actual account on our system for the customer as it is only for one transaction. Bascailly everything goes into one pooled account and it becomes a matter of accounting.



We have a signed agreement to settle this transaction from the customer. do you think that agreement needs to have a Reg E disclosure? or could it be exempt because no actual account is established for the customer on the banks books?

Sounds like the bank is acting as a third party processor. Is that the situation?