We have been told that we need to update our EFT disclosure to include information on electronic check conversions, certain computer-initiated bill payments, and fees associated with returned check entries. Does anyone have information on this or can you tell me where I can find information on the subject? Does Reg E have this information yet in their sample disclosure??

A change was made to Reg. E last year, with a mandatory compliance date of 1-1-02. Unfortunately, there is no model language for the check conversion. The other changes will fit in the model language currently in the regulation. If you conduct a search on this forum using the key words "check conversion" you will find a string that addresses this issue along with some "off the cuff" sample language.

You need to be careful if you use Reg E model language. In the confidentiality section, the last clause reads that you will only disclose information to third parties about the account: "If you give us your written permission". So, unless the situation falls under one of the earlier clauses (completing transfers, verifying account or in response to government orders) you have disclosed an "opt-in" requirement for release of information instead of the "opt-out" in your GLB notice.

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This is a personal observation that should not be taken as legal advice nor relied upon for any purpose.