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#2265487 - 01/31/22 02:57 PM Deposit Transfer Notice
Web Offline
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Joined: May 2005
Posts: 316
Are we required to provide a notice to customers when they make an internal transfer from deposit accounts at our bank or does the monthly statement satisfy this.

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Deposits and Payments
#2265493 - 01/31/22 05:17 PM Re: Deposit Transfer Notice Web
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,285
Illinois
If the transfers are covered by Reg E because they are performed through internet banking, then 1005.10(a) says you must provide a phone number for the customer to call to verify that the transfer occurred.

Internal transfers are not subject to Reg E so any notice requirements would be based on your deposit agreement. There is no federal regulation that requires notice each time a transfer is made.
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#2265668 - 02/02/22 08:46 PM Re: Deposit Transfer Notice BrianC
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted by BrianC
If the transfers are covered by Reg E because they are performed through internet banking, then 1005.10(a) says you must provide a phone number for the customer to call to verify that the transfer occurred.

Internal transfers are not subject to Reg E so any notice requirements would be based on your deposit agreement. There is no federal regulation that requires notice each time a transfer is made.

Section 1005.10 only addresses pre-authorized EFTs (authorized to occur repeatedly), so the phone number info access doesn't apply here.

"Home banking equipment" is not an electronic terminal because it's analogous to using a telephone. Remember that much of Regulation E was written before home computers and the Internet became available. No receipt is required. See comment 2(h)-1.

A transfer between in-house accounts made in today's world using the bank's online banking portal is subject to Reg E and you need to include appropriate descriptions for those transfers on statements, but there is no receipt requirement.
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