We are in the beginning phase of allowing P2P and have a couple of questions. 1-is sending an updated reg e disclosure to all customers in advance sufficient or should it be sent/given when the customer requests the addition of P2P? 2-what is the bank’s responsibility when the customer sends the wrong amount via P2P (we envision adding a zero or missing the decimal)?

7(a) Timing of Disclosures

1. Early disclosures. Disclosures given by a financial institution earlier than the regulation requires (for example, when the consumer opens a checking account) need not be repeated when the consumer later enters into an agreement with a third party to initiate preauthorized transfers to or from the consumer's account, unless the terms and conditions differ from those that the institution previously disclosed. This interpretation also applies to any notice provided about one-time EFTs from a consumer's account initiated using information from the consumer's check. On the other hand, 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.