We will soon be allowing our mobile banking customers to electronically transfer funds via P2P and A2A. There will be limitations on the amount of transfers a customer can make in a day so the 1005.7(b)(4) required initial disclosures will come into play. Section 1005.7 (c) requires disclosure of these limitations when adding an EFT service, but it doesn't give much direction on how to disclose the limitations. Can the disclosures required under 1005.7(c) be disclosed in the service agreement (contract) that the customer agrees to when requesting this service?

I see no problem with that. There are no disclosure segregation requirements under regulation E. If the consumer may not accessed the Regulation E services without executing and receiving a copy of the service agreement that contains the required disclosures and they can retain a copy. I think that would be a pretty common practice rather than dumping that information in your general Regulation E disclosure, which is given to many customers that will never use the service.

If the intent is to upsell consumers to use these services much like when debit cards were new and banks wanted to get them out there, adding it to the general, initial disclosure is the way to go. That simplifies the consumer who decides they want to use it when they first want to use it and not having to wait to call and sign up during a regular business day. More than once I've had someone say "I can Zelle you..." (insert whatever service you want) and I have b trying to get that payment I hate to say no I don't use it.