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#1901198 - 02/28/14 05:13 PM Reg E
amberleigh Offline
Junior Member
Joined: May 2011
Posts: 34
Kansas
We provide the Reg E disclosure when the account is first opened. If a customer comes in 6 months later and wants to order a debit card and we have had no changes to our disclosure since the account was opened, do we have to provide them with another Reg E disclosure?

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Operations Compliance
#1901221 - 02/28/14 05:27 PM Re: Reg E amberleigh
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,011
Illinois
Reg E 1005.7(a) and the commentary. The "close proximity" clause says that new disclosures should be made. For this reason many institutions have their EFT dislcousre attached to their ATM/debit card application.

Timing of disclosures. A financial institution shall make the disclosures required by this section at the time a consumer contracts for an electronic fund transfer service or before the first electronic fund transfer is made involving the consumer's account.


1. Early disclosures. Disclosures given by a financial institution earlier than the regulation requires (for example, when the consumer opens a checking account) need not be repeated when the consumer later enters into an agreement with a third party to initiate preauthorized transfers to or from the consumer's account, unless the terms and conditions differ from those that the institution previously disclosed. This interpretation also applies to any notice provided about one-time EFTs from a consumer's account initiated using information from the consumer's check. On the other hand, if an agreement for EFT services to be provided by an account- holding institution is directly between the consumer and the account-holding institution, disclosures must be given in close proximity to the event requiring disclosure, for example, when the consumer contracts for a new service.
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