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#2237439 - 06/01/20 07:23 PM Reg E Periodic Statement Content
Cats Meow Offline
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Joined: Jan 2017
Posts: 11
If a bank does not include their telephone number with the preface similar to "Direct Inquiries to" on the first page of the periodic statement, but instead only includes the phone number on the Error Resolution Notice on the back page, does that still satisfy Reg E at 1005.9(b)(5) and (6):

9(b)(5) Address and Telephone Number for Inquiries
1. Telephone number. A single telephone number, preceded by the “direct inquiries to” language, will satisfy the requirements of § 1005.9(b)(5) and (6).

9(b)(6) Telephone Number for Preauthorized Transfers
1. Telephone number. See comment 9(b)(5)-1.

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#2237547 - 06/03/20 09:20 PM Re: Reg E Periodic Statement Content Cats Meow
Diane Dean Offline
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Joined: Oct 2012
Posts: 92
I think where you'll have an issue is compliance with §1005.9(b)(6). You can use a single phone number under Direct Inquiries to satisfy both §1005.9(b)(5) and §1005.9(b)(6). You can also use the address and phone number with the error resolution notice to satisfy §1005.9(b)(5):

Address and telephone number for inquiries. The address and telephone number to be used for inquiries or notice of errors, preceded by “Direct inquiries to” or similar language. The address and telephone number provided on an error resolution notice under §1005.8(b) given on or with the statement satisfies this requirement.

So, while the address and telephone number for the error resolution language can satisfy the requirement under "Direct Inquiries to", I don't think it satisfies the telephone option for preauthorized transfers under §1005.9(b)(6).
_________________________
Diane Dean
http://www.bankerscompliance.com

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#2238556 - 06/24/20 02:42 PM Re: Reg E Periodic Statement Content Diane Dean
Cats Meow Offline
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Joined: Jan 2017
Posts: 11
Thank you, Diane!

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