Hi y'all

I have a question I am hoping I can get some feedback on.

I see that 1005.9b lays out the requirements for transfer information on periodic statements. Specifically under 1005.9bv1 I see where it says "the name of any third party to or from whom funds were transferred."

The interpretation under #2 states "If a consumer makes an electronic fund transfer to another consumer, the financial institution must identify the recipient by name (not just by an account number, for example).

My question(s):
1. Does this apply to internal, external or both transfers?
2. What is acceptable use of the name? (first and last, first initial last?)
3. If we elect to list the account number, are we running afoul of Reg E?

Thanks!

Also, I had seen this post, but thought I might ask anyway...

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=310779

1) Any third party, so internal or external as long as the transfer went to/from someone other than the account holder(s).

2) You can only display what was entered or provided in the transfer... if an ACH comes in and the originator is "J Doe" that what you state. If it shows John Doe, that's what you put.

3) No (assumption is you are talking about the account number of the third party). It's not required, but not prohibited either.

Thanks very much!