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#654630 - 12/20/06 02:19 PM Electronic Check Conversion
angels2mom Offline
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angels2mom
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I need clarification...In th appendix to Reg E where the "Model Clauses" are listed...does A-6 "Model Clauses for Authorizing One-Time Electronic Fund Transfers Using Information from a Check" apply to us as a financial institution or to the merchant accepting the check for payment?
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#654822 - 12/20/06 05:03 PM Re: Electronic Check Conversion angels2mom
John Burnett Offline
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John Burnett
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It applies to the merchant who plans to convert the customer's check to an ACH item. Your disclosure obligation relating to check conversions is in making sure your account disclosures list ACH transfers initiated by converting the customer's check as a form of EFT that can affect the customer's account.

Of course, if your institution converts checks it receives to ACH entries (loan and mortgage payments, credit card payments, etc.), you'd put yourselves in the place of the merchant, and have to use the model language in Model Clause A-6 (and possibly A-8).
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#654879 - 12/20/06 05:55 PM Re: Electronic Check Conversion John Burnett
angels2mom Offline
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angels2mom
Joined: Dec 2005
Posts: 338
Depends on my mood
Thanks John...that's what I thought...we are not doing an conversion so I posed the question to an examiner and got deer in head lights look followed by "yeah, you need to have that in your disclosure". I think it was an off the cuff answer because he didn't know.
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