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#792776 - 08/10/07 04:59 PM New Reg E rule
kira Offline
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Has anyone seen an update to reg E regarding issuing receipts on transactions under $15?

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#792803 - 08/10/07 05:23 PM Re: New Reg E rule kira
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Final rule was published in the Federal Register on July 5, 2007 effective August 6, 2007. Copy of final rule available here: http://www.bankersonline.com/topstory/72fedreg/72fr36589.pdf
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#792850 - 08/10/07 06:04 PM Re: New Reg E rule RVFlyboy
kira Offline
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Thanks my ops people didn't pick that one up

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#794454 - 08/14/07 07:22 PM Re: New Reg E rule kira
jef8111 Offline
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Can anyone tell me if they plan on notifying their existing customers of this change by sending out addendums or statement stuffers?
I just received a call from Wolters Kluwer pressing me to place two orders.
1. Notify existing customers using a statement stuffer
2. Include an addendum in our Terms & Conditions to update our existing Reg E language.
Are other financial institutions doing this?

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#794460 - 08/14/07 07:27 PM Re: New Reg E rule jef8111
John Burnett Offline
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While I agree that you should update your account disclosures so that all new customers are informed they might not get a receipt for transfers of $15 or less, you can notify existing customers with a simple statement message. Why spend money for a printed stuffer?
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#795019 - 08/15/07 01:51 PM Re: New Reg E rule John Burnett
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#795020 - 08/15/07 01:52 PM Re: New Reg E rule LoisLane
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I put a note on our monthly statements, and also a note on our internet banking website...
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#795632 - 08/15/07 07:59 PM Re: New Reg E rule John Burnett
complygirl Offline
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So are we required to notify existing customers of this change or is it just "highly recommended"?

We do not plan on changing our ATM receipt procedures at our bank owned ATMs (we will continue to provide a receipt on all transactions), because of this our head of operations doesn't see the reasoning behind us notifying existing customers of this change. Any information on this would be appreciated.

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#796331 - 08/16/07 04:56 PM Re: New Reg E rule complygirl
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We received the same sales call from Walters Kluwer too and I think we will also pass on that expense item and do the statement message/online banking notice. I am not seeing model language for this part of the initial disclosure that we would be required to change? I agree about the customer service issue though.

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#800961 - 08/23/07 01:57 PM Re: New Reg E rule Rangers Fan
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I'm with complygirl. If we continue to provide receipts on all ATM transactions what would we have to notify customers about? Can we keep things as they are now and continue to provide all receipts???

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#800971 - 08/23/07 02:05 PM Re: New Reg E rule HR Banker
John Burnett Offline
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I posted this OPINION in one of the private forums, so I'll copy it here, rather than simply link to it.

Quote:
OK. Here's my take on the receipts disclosure.

The language that most issuers use in their "initial disclosures" under § 205.7(b)(6) is lifted directly from the model disclosures in Appendix A to Regulation E (A-2(g), specifically). I don't agree that the model language accomplishes what it's supposed to cover. The regulation requirement is that this disclosure provide "A summary of the consumer's right to receipts and periodic statements, as provided in Sec. 205.9, and notices regarding preauthorized transfers as provided in Secs. 205.10(a), and 205.10(d)." That right includes receipts at all ATMs and POS terminals that can be accessed with the card, not only those operated by the card issuer.

The model language has apparently been enough to satisfy examiners, auditors, et al for years. Now there is an amendment that creates an exception. Why the Fed didn't send out a change to the model language is anyone's guess, but I won't presume to say that it's because the Fed Staff doesn't think issuers need to update their disclosures. There's no mention of § 205.7(b)(6) disclosures in the Fed's Federal Register publication of the amendment, so we don't know if Fed Staff even considered the question.

Remember -- use of the model language only covers you if it reflects your actual practices.

What's the purpose of disclosures? One view is that the purpose is to keep the bank out of trouble. Another view, and the one I espouse, is that disclosures are made to inform consumers. For that reason, I believe that the bank has a duty to make its disclosures informative (but within the limits of the regulations). That, in my view, includes telling consumers they may not get a receipt at some terminals for transactions of $15 or less.
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#800987 - 08/23/07 02:17 PM Re: New Reg E rule John Burnett
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So even if we will continue to give receipts on all transactions are you saying we still need to inform the customer so that when they use their debit card at Walmart and don't get a receipt they will understand why?

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#801057 - 08/23/07 03:02 PM Re: New Reg E rule HR Banker
John Burnett Offline
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That is my OPINION.
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#801194 - 08/23/07 04:55 PM Re: New Reg E rule HR Banker
ahou Offline
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I'm thinking about changing our disclosure to include words in blue:

Generally,a receipt will be provided to you at the time you make any transfers to or from your account using your card. Federal law does not require a receipt for transactions $15 or less.
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#801342 - 08/23/07 05:56 PM Re: New Reg E rule ahou
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Here is my recommendation from the same thread John is referring to.

"You can get a receipt at the time you make any transfer greater greater than $15 to or from your account using one of our [automated teller machines] [or] [point-of-sale terminals]."

The bold text is my addition to the model language. I try to do as little modification to that safe harbor friend as possible.
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#801416 - 08/23/07 06:36 PM Re: New Reg E rule Andy_Z
John Burnett Offline
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I agree with Andy about making minimal deviations from the model disclosures. In this case, however, to more accurately state the customer's right, I'd alter it ever so slightly and make the statement read:

"You can get a receipt at the time you make any transfer greater greater than $15 to or from your account using a[n] [automated teller machine] [or] [point-of-sale terminal]."

My change assumes your bank participates in one or more networks.
Last edited by John Burnett; 08/23/07 06:37 PM.
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#801481 - 08/23/07 07:22 PM Re: New Reg E rule John Burnett
bcastle Offline
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I am notifying all employees of the change so they will be prepared to answer any customer comments or concerns, putting notice on our website and have gotten wolters kluwer to make the changes to our AIB and Card-Bro disclosures on Platform.
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#805883 - 08/30/07 03:02 PM Re: New Reg E rule bcastle
susie spongehead Offline
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We still plan to give receipts at our ATMs for all transactions. Because of this we were not sure if we wanted to go the expense of updating our EFT disclosure. Especially since we recently revised our debit card agreement to include the EFT disclosure... we use give two seperate forms.

Anyway I happen to live in a city that has a FRB Branch so I contacted a examiner there. The examiner's response is below:

Quote:
Hi ......,

You would think that when the powers that be enacted this change to the regulation they would come up with some model language. However, the model language in Appendix A-2 (g) notes that "You can get a receipt at the time you make any transfer to or from your account using one of our" ATMs or POS terminals. Since the bank is going to continue to provide the ATM receipt for withdrawals regardless of the dollar amount, I would say that the bank would not need to change their disclosures.
Quote:


I think it is a good idea to notify customers of the change by posting a notice on our website and in our lobby. We will look at changing the EFT disclosure next year when we update our disclosures.
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#816345 - 09/17/07 02:53 PM Re: New Reg E rule complygirl
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While various posters are "recommending" or "suggesting" we notify our existing customers (through a statement message) are we required to under the law?

I have also notified our branch staff in the event they receive customer questions, but would like to put this to bed without notifying our exising customers, if possible. We currently have other statement messages running.

I have already updated my Terms and Conditions disclosure for new accounts going forward to state something like "you may not receive a receipt if your transaction is $15 or less."

Is a notice to existing customers required????

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#816782 - 09/17/07 09:09 PM Re: New Reg E rule travelgirl
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No. Check out our September e-newsletter (it's free!) for more info. http://www.bankerscompliance.com/compliance-resources/newsletters_.htm
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#817016 - 09/18/07 02:32 PM Re: New Reg E rule David Dickinson
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Thanks for the response David and for the newsletter lead. I'm all signed up!

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