Are Venmo and Zelle included under Reg E opt in / opt out rules. Are the only transactions that require an opt in / opt out are ATM and one time debit? Thanks!

§1005.17 only applies to overdraft fees triggered by ATM and one-time debit card transactions.

Thanks John. I think the question comes from this Law Decision:
https://www.americanbar.org/content...article-innovation-in-banking-202010.pdf

See pages 5-7

I'm not sure you can just call it a Venmo transaction or a Zelle transaction. You have to determine how the request to debit the consumer's account is transmitted to the bank. I think most Venmo and Zelle transactions are actually either: a) one time debit transactions; or b) ACH debit entries.

Exactly Rainman

So if it posts as a debit card transaction because I attached by debit card to the Venmo or Zelle account, it is covered by Reg E 1005.17. If I use my routing number and checking account number and the transaction posts as ACH, it is not covered.

Brian, do the opt in rules then apply for the Reg E transactions?

Debit card: Yes
ACH: No