Good morning!
I apologize but 4 months have passed and I don't remember exactly what I sent; however I will say that we did reach out to 'experts' and were told we needed to not only add this information to our Regulation E disclosure, but had to provide the new disclosure to anyone who signed up for the service. This part of Regulation E was highlighted and returned:
Section 1005.7(a) states that “A financial institution shall make the disclosures required by this section at the time a consumer contracts for an electronic fund transfer service or before the first electronic fund transfer is made involving the consumer's account.â€
The commentary to this part states….†if an agreement for EFT services to be provided by an account- holding institution is directly between the consumer and the account-holding institution, disclosures must be given in close proximity to the event requiring disclosure, for example, when the consumer contracts for a new service.â€
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