The OCC's testing of Reg. E poses a question I cannot find the answer to in the reg itself. The question is: "If a third party with whom the consumer contracts for preauthorized debits or credits is not a bank, does the account holding bank, per adopted procedures, provide the initial disclosures?" Can anyone shed some light on this one for me?

That means that if the account can be accessed by third parties via ACH, have you given them Reg. E disclosures.

On the other hand, consider what happens if your customer signs up with Exxon/Mobil for a SpeedPass transponder fob, and provides his debit card information for use with the Speedpass. ExxonMobil is responsible, under 205.14, for providing product-specific disclosures about Speedpass.