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#2225441 - 11/12/19 04:05 PM Mobile Wallet
ItsJustMe Offline
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Joined: Dec 2009
Posts: 298
New York
Is mobile wallet a service that would be covered under Regulation E? I'm really not sure, trying to understand how it works and whether it even falls under the definition of an EFT. Or, could it simply be covered under "mobile banking"?

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#2225442 - 11/12/19 04:16 PM Re: Mobile Wallet ItsJustMe
BrianC Online
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BrianC
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Illinois
Who is offering the mobile wallet, the bank or a third party such as Paypal or Venmo? What types of transactions can be performed?
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#2225443 - 11/12/19 04:21 PM Re: Mobile Wallet ItsJustMe
ItsJustMe Offline
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Joined: Dec 2009
Posts: 298
New York
It appears we use a third party. This is what the terms and conditions state... thoughts?:

A Mobile Wallet Service (“Wallet”) allows you to add your Cards to an application using your Mobile Device. Your Card number is replaced with a digital number or token. Once added, you understand that you may use your Mobile Device to make payments only where the Wallet is accepted. We are not a provider of the Wallet and we are not responsible for any failure or inability to perform a transaction using the Wallet. We are only responsible for supplying information securely to the Wallet provider to allow usage of the Card in the Wallet.

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#2225462 - 11/12/19 07:38 PM Re: Mobile Wallet ItsJustMe
ItsJustMe Offline
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Joined: Dec 2009
Posts: 298
New York
Anyone care to weigh in with their thoughts? Do you feel this would be something that requires an EFT disclosure?

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#2225484 - 11/12/19 09:23 PM Re: Mobile Wallet ItsJustMe
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
From them - yes - from you, I would think not.
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#2225494 - 11/12/19 09:46 PM Re: Mobile Wallet ItsJustMe
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
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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www.tcaregs.com

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#2225496 - 11/12/19 09:56 PM Re: Mobile Wallet ItsJustMe
ItsJustMe Offline
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Joined: Dec 2009
Posts: 298
New York
thanks to both... we do contract with the third party so I'll start working on creating the EFT disclosures

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