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#1755961 - 11/07/12 04:16 PM Remittance Disclosures
gonetobeach Offline
100 Club
gonetobeach
Joined: May 2004
Posts: 132
near Dallas
Since remittances are now (or will be) brought in under Reg E, should anything be added to the current Reg E disclosure that is provided to customers at account opening? A "Change in Terms" notice required since new products are now available and protected under Reg E? Should the Error Resolution Notice sent to consumers be updated to reflect the Remittance error resolution process? Online banking agreements updated?

Also, if we change our wire fees (that we list on our Fee Schedule) - would that require a change in terms under Reg DD?

Or am I way off base and need to be looking at this process as a new product/service being offered and disclosures are only required at the time the remittance is ordered/transacted?

Any help will be appreciated. I am only confusing myself!!

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eBanking / Technology
#1755967 - 11/07/12 04:20 PM Re: Remittance Disclosures gonetobeach
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
Wire transfers are not an on-going product. They come one at a time. They are not covered under Reg. DD and and there is no need to modify your current Regulation E disclosure.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1755978 - 11/07/12 04:27 PM Re: Remittance Disclosures gonetobeach
gonetobeach Offline
100 Club
gonetobeach
Joined: May 2004
Posts: 132
near Dallas
Thank you Randy! I think my mind is just on overload right now!

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