The caveat is whether or not the bank has contracted with the third party. For example, if we contract with Apple Pay or Zelle to allow customers to mobile wallet transfers through our internet/mobile banking platform, then we owe the customer disclosures. If the customer is contracting through a third party themselves, (such as a PayPal, Venmo, Google Wallet) then the third party owes the customer disclosures and the third party would be subject to the requirements of 1005.14.
In all cases, transfers through these platforms are covered by Reg E, but how the product is set up dictates who has the compliance responsibilities.
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