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#2240153 - 07/24/20 09:55 PM Reg E Initial Disclosure + Types of EFTs available
NoJustNo Offline
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Posts: 189
Midwest
Reg. E wants you to disclose the "type of electronic fund transfers that the consumer may make..." and then provides no examples. How specific should we get here?

If the definition states of an EFT is: "The term “electronic fund transfer” means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account. The term includes, but is not limited to:(i) Point-of-sale transfers; (ii) Automated teller machine transfers; (iii) Direct deposits or withdrawals of funds; (iv) Transfers initiated by telephone; and (v) Transfers resulting from debit card transactions, whether or not initiated through an electronic terminal."

It would seem that each of the terms directly mentioned should be disclosed (if applicable) -- but what else are you including?

Internet banking? Mobile deposit? I just don't know how far to go....

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#2240154 - 07/24/20 10:05 PM Re: Reg E Initial Disclosure + Types of EFTs available NoJustNo
rlcarey Offline
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rlcarey
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Galveston, TX
Have you looked at Appendix A - Model A-2 Section (d)?

https://www.bankersonline.com/regulations/12-1005-appa#A2
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#2241145 - 08/17/20 06:47 PM Re: Reg E Initial Disclosure + Types of EFTs available NoJustNo
NoJustNo Offline
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Joined: Oct 2013
Posts: 189
Midwest
I have - but it seems that the appendix is very, very limited. I see some banks identify methods like telephone banking, bill pay, mobile baking, mobile check deposit, online banking, etc. ... and then specify the types of transactions. It's hard to know how far to go. For example, I can see the viewpoint of "bill pay" or "mobile check deposit" falling under "online banking."

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#2241214 - 08/18/20 08:04 PM Re: Reg E Initial Disclosure + Types of EFTs available NoJustNo
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,346
Cape Cod
"Mobile check deposit" is not an EFT.
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