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#2249129 - 02/11/21 08:19 PM Text Messaging & Reg E
MJNoone Offline
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MJNoone
Joined: Dec 2010
Posts: 94
Kansas
You never realize how antiquated some of our regulations are until you read about "magnetic tapes" laugh

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)?
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eBanking / Technology
#2249137 - 02/11/21 08:51 PM Re: Text Messaging & Reg E MJNoone
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,017
Illinois
A transfer by text is the same as a transfer by internet banking or telephone touch tone transfer software. It's a covered EFT.

A non-covered transfer by telephone is when I dial the bank's customer service line using my rotary phone and ask the representative to transfer funds for me.
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#2249144 - 02/11/21 09:20 PM Re: Text Messaging & Reg E MJNoone
MJNoone Offline
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MJNoone
Joined: Dec 2010
Posts: 94
Kansas
Thank you Brian C for the clarification!
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#2249554 - 02/22/21 09:59 PM Re: Text Messaging & Reg E MJNoone
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
Brian's phone doesn't need to be a rotary dial. Brian could just like talking to a human to get the transfer done. It would still be non-EFT. In fact, Brian could use a smart phone to make the same call and have the transfer handled manually. But he might get faster service if he used the computer capabilities of his smart phone to do it himself and receive an instant confirmation that it's done. That would be an EFT.
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