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#2218139 - 07/22/19 03:39 PM REG E and Bill Pay
Tanders922 Offline
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Joined: Sep 2015
Posts: 121
Just need confirmation that bill pay disputes would follow the REG E dispute process, correct?

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eBanking / Technology
#2218153 - 07/22/19 05:20 PM Re: REG E and Bill Pay Tanders922
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Sure. If they meet the definition of "Unauthorized electronic fund transfer" in §1005.2(m).
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2218154 - 07/22/19 05:22 PM Re: REG E and Bill Pay Tanders922
Tanders922 Offline
100 Club
Joined: Sep 2015
Posts: 121
that's what I thought.. thanks!

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#2289250 - 09/29/23 03:08 AM Re: REG E and Bill Pay Tanders922
c@c Offline
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Joined: Mar 2008
Posts: 120
Georgia
Following up on this old thread - is this specific to the bank's bill pay service offered through online banking? And does it matter how the item clears the customer's account? For example, our bill pay provider has the right (per contract) to pay the bill electronically, by paper draft, or by corporate check (drawn on the bill pay provider's account). Clearly an ACH transaction is going to be a Reg E item, but will the paper draft (item clears the customer's account as a check) also be something we need to handle as Reg E if there is a dispute? And for items paid by corporate check as well?

There is commentary in Reg E that speaks to bill pay scenarios but it is rather confusing.

I'm assuming (hoping) Reg E would not be applicable to situations where the customer disputes a paper draft that was NOT created through bank's bill pay provider. Those would be remotely created check disputes.

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