Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#2109745 - 12/05/16 10:52 PM Reg. E - Monthy Statement Online Banking Transfers
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 540
Scenario 1: Customer has online banking transfers from one account to another within the bank.

Scenario 2: Customer has external transfer set up through online banking to transfer from account at our bank to an account another financial institution.

Do either of these scenarios trigger the Reg. E requirement to provide a monthly periodic statement do to EFT activity? Thanks.

Return to Top
Operations Compliance
#2109748 - 12/05/16 11:26 PM Re: Reg. E - Monthy Statement Online Banking Transfers TeamComply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Both.

On scenario #1: (2) Intra-institutional transfers. For an electronic fund transfer initiated by the consumer between two accounts of the consumer in the same institution, documenting the transfer on a periodic statement for one of the two accounts satisfies the periodic statement requirement.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2109777 - 12/06/16 02:36 PM Re: Reg. E - Monthy Statement Online Banking Transfers rlcarey
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 540
Thanks rlcarey. And for scenario 1 the statement must be monthly or would a quarterly statement with the transfer information be sufficient?

Also, could you provide a regulatory citation?

Return to Top
#2109790 - 12/06/16 03:48 PM Re: Reg. E - Monthy Statement Online Banking Transfers TeamComply
BrianC Online
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
Reg E 1005.3(b) notes that transfers initiated through a computer are covered EFTs.

(b) Electronic fund transfer. (1) Definition. The term “electronic fund transfer” means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account.

Reg E 1005.9 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.

If you have an internet banking transfer, then you owe the customer a monthly statement.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top

Moderator:  Andy_Z, John Burnett