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#739847 - 05/24/07 06:44 PM Reg E statement descriptions on periodic stmts
Nick Phillips Offline
Junior Member
Joined: Apr 2003
Posts: 43
illinois
in the middle of an exam here.....

as you know, we are required to provide FULL documentation on the periodic statements stating the address of the debit card transaction and third party name (ex. Walgreens).

What do you do if the information is not passed from the merchant to our system?

I have been sited for not supplying the required REG E information but I am not getting this information from the merchant.

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General Discussion
#739856 - 05/24/07 06:53 PM Re: Reg E statement descriptions on periodic stmts Nick Phillips
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
Um, I don't believe that the ADDRESS is required. From the Reg:

(5) Terminal location. The location of the terminal where the transfer is initiated, or an identification such as a code or terminal number. Except in limited circumstances where all terminals are located in the same city or state, if the location is disclosed, it shall include the city and state or foreign country and one of the following:

(i) The street address; or

(ii) A generally accepted name for the specific location; or

(iii) The name of the owner or operator of the terminal if other than the account-holding institution.

Paragraph 9(a)(5) —Terminal Location

1. Options for identifying terminal. The institution may provide either:

i. The city, state or foreign country, and the information in §§205.9(a)(5) (i), (ii), or (iii), or

ii. A number or a code identifying the terminal. If the institution chooses the second option, the code or terminal number identifying the terminal where the transfer is initiated may be given as part of a transaction code.

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#739911 - 05/24/07 07:28 PM Re: Reg E statement descriptions on periodic stmts MN Banker
Nick Phillips Offline
Junior Member
Joined: Apr 2003
Posts: 43
illinois
thanks for the information. I meant to center my question more on the debit card used at a merchant or business.

some debit card purchases don't have much information at all, maybe an address etc. I am printing two full lines of information which I have proved is the information that is coming to me from the processor, but the auditor is saying that is not enough.

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#740795 - 05/25/07 06:27 PM Re: Reg E statement descriptions on periodic stmts Nick Phillips
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,697
Cape Cod
Take a look at Comment 1 to section 205.9(b)(1) in the Official Staff Interpretations to the Reg.

You can, after the fact, contact your processor to determine where the problem lies. There are often several hands that touch POS transactions, and any one of them could be the problem.
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