Skip to content
BOL Conferences

Thread Options
#2044682 - 10/16/15 05:12 PM Truncated account numbers
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
Can anyone point me in the right direction to get clarification on the issue of truncated account numbers on periodic statements? I found information on this regarding receipts and credit card numbers. Also found reg E 205.9(b) referring to the account number required on the statement. But no elaboration if truncated account numbers are allowed.
Any help is appreciated.

Return to Top
Operations Compliance
#2044734 - 10/16/15 06:36 PM Re: Truncated account numbers Banker57
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
First, get yourself out of the habit of digging into the Federal Reserve's dead Regulation E. The rule belongs to the CFPB (since December 2011), and it's been amended a few times, so use the Bureau's Regulation E at 12 CFR Part 1005. The section you referred to hasn't changed since the rule was reissued by the CFPB, however.

There's one place in the same regulation where the concept of account number truncation is mentioned. Ironically, its also in section 1005.9, but it's in 1005.9(a), concerning EFT receipts at electronic terminals, including ATMs. There, we see that the receipt's identification of the account number or access device can be truncated to as few as four digits. Why the Fed (they are the folks that added that truncation option decades ago) didn't do anything about approving the truncation of the account number on statements is anyone's guess. The Fed recognized that lots of ATM receipts were being tossed out with account numbers on them, and they were concerned about it. That was the gist of the discussion about the change in the Federal Register document. They apparently didn't consider that full numbers on statements is as big a problem, perhaps because they didn't think people are as careless with statements as they are with receipts. Or they may not have thought about statements.

Anyhow, the regulation calls for the account number to be on the statement. There's nothing to say that it can be truncated. You might observe that there's nothing preventing truncation, either. You'd be right. I think the key to this question is whether you and your customer can identify which account is involved in a statement if the number is "clipped."
Last edited by John Burnett; 10/16/15 06:38 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2044737 - 10/16/15 06:41 PM Re: Truncated account numbers Banker57
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I'll add this: Although I cannot prove this, I am comfortable saying that no one has been cited or penalized for truncating the account number on the statement.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2044751 - 10/16/15 07:09 PM Re: Truncated account numbers Banker57
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
John,
Thank you for this information! Sometimes I dig myself a hole the more I search....

Return to Top
#2303059 - 11/06/24 02:06 PM Re: Truncated account numbers Banker57
Tanders922 Offline
100 Club
Joined: Sep 2015
Posts: 124
John - is this still the true - truncating is not required on the statement, however, no one has been cited or penalized for truncating account number on the statement?

Return to Top
#2303062 - 11/06/24 02:28 PM Re: Truncated account numbers Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 84,678
Galveston, TX
I have not heard of anyone being cited. My bank truncates all but the last four digits on all periodic statements.

While Regulation E does not specifically address this, if you look at the underlying statute (15 U.S. Code ยง 1693d - Documentation of transfers) the account number is not even a requirement on the periodic statement provided. I think with all the fraud going on, any regulatory risk is very limited.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2303067 - 11/06/24 02:49 PM Re: Truncated account numbers Banker57
Tanders922 Offline
100 Club
Joined: Sep 2015
Posts: 124
So truncation is a risk decision and there's no regulatory position directly related to truncation?

Return to Top
#2303070 - 11/06/24 03:03 PM Re: Truncated account numbers Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 84,678
Galveston, TX
All you have is this:

1005.9(b) Periodic statements. For an account to or from which electronic fund transfers can be made, a financial institution shall send a periodic statement for each monthly cycle in which an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred. The statement shall set forth the following information, as applicable:

(2) Account number. The number of the account.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2303071 - 11/06/24 03:06 PM Re: Truncated account numbers Banker57
Tanders922 Offline
100 Club
Joined: Sep 2015
Posts: 124
Great thank you!

Return to Top

Moderator:  Andy_Z, John Burnett