The Reg E provision below requires notice be sent to customer when a person initiates preauthorized electronic fund transfers to a consumer's account at least once every 60 days OR that a phone number be posted on the initial disclosure and periodic statements. Question: Is simply having your phone number on the periodic statement sufficient or do you need to include some language like the following?

Thanks!


PREAUTHORIZED TRANSFERS: If you have arranged to have preauthorized transfers made to your account at least once every 60 days from the same person or company you can call us at (800) 222-2222 to find out whether or not the transfer has been made.



§ 205.10 Preauthorized transfers.

(a) Preauthorized transfers to consumer's account--(1) Notice by financial institution. When a person initiates preauthorized electronic fund transfers to a consumer's account at least once every 60 days, the account-holding financial institution shall provide notice to the consumer by:

(i) Positive notice. Providing oral or written notice of the transfer within two business days after the transfer occurs; or

(ii) Negative notice. Providing oral or written notice, within two business days after the date on which the transfer was scheduled to occur, that the transfer did not occur; or

(iii) Readily-available telephone line. Providing a readily available telephone line that the consumer may call to determine whether the transfer occurred and disclosing the telephone number on the initial disclosure of account terms and on each periodic statement.

Take a look at the Model Disclosures in section A-2 of Appendix A, Regulation E, and scroll down to paragraph (g). There you'll find a model paragraph for account disclosures covering the section 1005.10(a) requirement. Of course, as the account-holding institution, you have no way of knowing whether the person initiating the preauthorized EFT credits will notify the consumer. It's likely in the case of payrolls. But it won't happen for recurring Federal benefits payments. No bank I know of still notifies customers of receipt of such transfers (positive notice) and I cannot remember the last time I heard of a bank offering negative notices. So that leaves the telephone line option, which doesn't, by the way, require repeating on monthly statements.

You could even say that "Some persons making such transfers will notify you; you can ask us if a transfer has been received by telephoning us at 1 (800) EFT-BANK during business hours, from 6 a.m. until 8 p.m. Monday through Saturday." [Customize the number and hours to your bank's situation]

Thank you!