Are the bill pay checks drawn on the consumer's account or on a central account held by the bank or a vendor?
If drawn on the consumer's account, and the consumer was informed when signing up for bill-pay that all payments will be solely by check on the consumer's account, the payments will not be covered by Reg E. In that case, they will be covered by the UCC as unauthorized checks instead of being covered by Reg E.
So, if the payments were not authorized by your customer, it's really a matter of which pocket the bank will reimburse the customer from -- the EFT pocket or the paper check pocket.
Last edited by John Burnett; 12/17/18 02:16 PM.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8