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#604292 - 08/24/06 02:45 PM Regulation E ???
GorgeS Offline
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Joined: Apr 2004
Posts: 203
If a transaction is initiated via our bill pay product via the internet but the company we use to issue the requested payments issue those payments via a papercheck, does Regulation E apply? My understanding when it comes to the company that we use, they issue about 95% of all requested payments via a papercheck not electronically. thanks

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eBanking / Technology
#604293 - 08/24/06 03:23 PM Re: Regulation E ???
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 38,772
Cape Cod
Yes, George. Unless the paper check is drawn on the consumer's own account and you disclose to the consumer that this is the way these payments are handled, the bill payment transaction is subject to Regulation E.

See the Interpretations to Regulation E in Supplement I, specifically, interpretation (vi) to paragraph 205.3(b)(1).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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