Most of our Savings accounts are set up for Quarterly statements with Monthly transcript statements in months in which there is an EFT. (Reg E 1005.9b) I was conducting a Reg E audit and confirming that transcript statements are produced when there are EFTs. I found one where there was an EFT on the last day of the month, but no transcript statement was produced.

We questioned this with our core provider and were given this answer:
"In order for a transcript statement to be produced for REG E , the transaction must post before last day of the month. The transaction posted on the 28th."

This is from the Core provider's Specification document:
"In order for the Reg E EOM statements to generate, Reg E transactions must post prior to the last day of the month."

From a Compliance standpoint, this does not make any sense to me. I guess I'm just looking for some support or confirmation that I'm not missing something before I go back to the core provider to try to argue this. It's not like the Reg says, "Hey, you have to give them a monthly statement, unless of course the EFT occurs on the last day of the month, then just don't worry about it!" ???

Hey Cindy,

Perhaps a bit late, but I agree. I do not see an "out" from the requirement to provide a periodic statement in this situation. It is not mentioned in any of the exceptions under 12 CFR 1005.9(c). As long as the EFT happened within the monthly "cycle," whether the last day or not, then a periodic statement would be required.

[(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 . . .]

[1. Periodic cycles. Periodic statements may be sent on a cycle that is shorter than monthly. The statements must correspond to periodic cycles that are reasonably equal, that is, do not vary by more than four days from the regular cycle. The requirement of reasonably equal cycles does not apply when an institution changes cycles for operational or other reasons, such as to establish a new statement day or date.]