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#2230921 - 02/12/20 09:21 PM Online Banking Agreement and Reg. E
TeamComply Offline
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Is there a regulatory requirement to include Reg. E items (such as error resolution, liability, etc.) into the Bank's Online Banking agreement?

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eBanking / Technology
#2230926 - 02/12/20 09:46 PM Re: Online Banking Agreement and Reg. E [Re: TeamComply]
rlcarey Online
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rlcarey
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Galveston, TX
Depends on whether your on-line banking services provides new EFT services and whether that is in close proximity to the last set of Reg E disclosures they received..

Official Interpretation

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.
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#2232098 - 02/28/20 10:31 PM Re: Online Banking Agreement and Reg. E [Re: TeamComply]
Andy_Z Offline
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Andy_Z
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Also, look at (b)(4) - are these new types of transfers that should be included in Reg E such as bill pay?

https://www.bankersonline.com/regulations/12-1005-007
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AndyZ CRCM
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