Skip to content
GeoDataVision
Learn More - Click Here!

Thread Options
#2214257 - 05/23/19 01:24 PM EFT Agreement and Signs up for a New Service
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
With regards to services that can facilitate an electronic transfer, is there a reasonable time period from account opening and providing the EFT disclosure that a consumer can enroll in these services and not have to have another EFT disclosure provided to them.

For example, consumer opens new account today and signs up for online banking - is given the EFT disclosure. Next week the customer signs up for the bill pay module in the online banking service. Must we provide another EFT disclosure (assuming it had not changed in the interim).

Can we set a reasonable time period such as 7 or 10 days from account opening if the EFT disclosure has not changed?
_________________________
Always learning something new...

Return to Top
Operations Compliance
#2214265 - 05/23/19 02:24 PM Re: EFT Agreement and Signs up for a New Service Likes to Comply
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
That sounds pretty reasonable to me. "Reasonable" is not defined in the regulation.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2214640 - 05/30/19 07:48 PM Re: EFT Agreement and Signs up for a New Service Likes to Comply
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,502
On the Net
7 to 10 days is certainly "reasonable" but if it was 7 to 10 months, maybe, 7 to 10 years, probably not. The easiest thing is to say if you have to ask, give the disclosure that costs you 2 cents.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top

Moderator:  Andy_Z, John Burnett