I have discovered that it appears that our mobile banking platform now allows customers to send money via Zelle. Has anyone incorporated commentary to this service within their Reg E, online or mobile banking agreements or disclosures, and if so how or to what extent?

Sending you a PM now.

Bump - same question as Just Jay.

Skittles - can you PM me as well? I also have some questions regarding the change-in-terms letter we are sending to customers.

Thank you!

Skittles can you PM as well?

Skittles, could you PM me as well. Thank you!

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.”
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.”

I'm not sure I understand all these terms but I've not gone thru it all either. This is not necessarily the disclosure your bank needs, but it's a resource and research.

https://www.wellsfargo.com/online-banking/transfers/zelle-terms/

https://www.kansascityfed.org/~/media/files/publicat/psr/briefings/psr-briefingjan2017.pdf

This hearkens back to the days of Marketing calling and letting you know the website went live at the first of last month.