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

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).