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#2215322 - 06/10/19 06:58 PM Mobile Wallet - EFT Agreement?
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
If someone registers their debit card in a mobile wallet such as Apple or Google Pay, must an EFT agreement be sent or are we ok since it was already given in conjunction with the issuance of the debit card?
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Operations Compliance
#2215326 - 06/10/19 07:15 PM Re: Mobile Wallet - EFT Agreement? Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
How would you know?
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#2215327 - 06/10/19 07:16 PM Re: Mobile Wallet - EFT Agreement? Likes to Comply
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,310
Illinois
You answer is found in the commentary to 1005.7.

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.

Since your customer is contracting with a third party, rather than the bank, for a new service, there is no need to redisclose.
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#2215343 - 06/10/19 08:28 PM Re: Mobile Wallet - EFT Agreement? Likes to Comply
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Joined: Nov 2008
Posts: 1,060
In the mountains
Thanks!
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