We provide a copy of the Reg E disclosure when a customer requests Online Banking. Once registered for Online Banking the customer may choose tp go to Apple or Google and download the Mobile Banking app. You can't access the app without OLB. The same login info etc is used to access either OLB or Mobile. Since the Reg E disclosure is handed to the customer when they register for OLB, is it required that they receive it again when they download the mobile banking app? And if yes, I would love to know how this is being accomplished. We don't know when someone adds MB as a way to access OLB.

Thank you in advance for your responses.

If your disclosures are current and all the services and limitations and contacts are disclosed, there is no need to redisclose as the consumer has been advised of what is applicable. In some cases a third party may be responsible for Reg E (1005.14) and they may make disclosures.

At the heart of the issue is that so long as you have made disclosures within a reasonable time and they are still accurate, there is no need to redisclose, although you are free to do so.