You never realize how antiquated some of our regulations are until you read about "magnetic tapes"
Researching Reg E for guidance on rather "text" messages that allow a customer to transfer funds between accounts is considered an EFT. We are looking at a product that will work hand-in-hand with our mobile banking app that will allow a customer to text certain key words (such as TRF) to move funds from one account to another (all within the same FI).
Would this type of transaction fall under the definition of EFT as a transfer "initiated by telephone" in 1005.3(b)(1)(iv) or be excluded under .3(c)(6)?
Does the EFT disclosure describing the service meet the "written plan" criteria in 1005.3(c)(6)?