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#2249227 - 02/15/21 07:09 PM Reg E - Statements Question
Johnny5 Offline
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Johnny5
Joined: May 2012
Posts: 64
In looking at a secured credit card product that requires a savings account to be opened at the time of account opening (uses as collateral for the credit card line amount), I'm trying to determine whether statements will be required for the savings account.

1005.9(b) simply provides:
(b) Periodic statements. For an account to or from which electronic fund transfers can be made, a financial institution shall send a periodic statement for each monthly cycle in which an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred.

Customers would be allowed to conduct a fund transfer with their initial deposit at account opening, and then the only other allowable transactions would be subsequent EFT deposits for approved credit line increases (increase savings deposit amount to new line amount). The bank would only release funds after processing an account closing.

Does the above mandate the requirement for periodic statements quarterly/monthly as a CLI occurs?

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#2249229 - 02/15/21 09:31 PM Re: Reg E - Statements Question Johnny5
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,712
Illinois
Unless this is a passbook account which only allows preauthorized credits (which also means you'd be updating passbooks upon customer request) then you must provide a periodically statement at least quarterly and also monthly for any periods that have an EFT deposit.
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#2249252 - 02/16/21 06:25 PM Re: Reg E - Statements Question BrianC
Johnny5 Offline
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Johnny5
Joined: May 2012
Posts: 64
Thanks for your response, Brian. Seems pretty straight forward but I was second guessing it when looking at a lot of terms and conditions for products out there today. I think they must bypass this requirement by how they structure the account, in structuring it as purely a security deposit.

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#2249253 - 02/16/21 06:38 PM Re: Reg E - Statements Question Johnny5
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,712
Illinois
If the Bank is holding the funds in escrow for the customer then I agree a periodic statement would not be needed.
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