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#1560396 - 06/03/11 05:23 PM One Time Reg E Disclosure
LawAnd Order Offline
Junior Member
Joined: Oct 2006
Posts: 43
When someone opens an account and receives a Reg E disclosure, is it required that they be provided another disclosure for any subsequent accounts they may open, if nothing has changed?

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Operations Compliance
#1560449 - 06/03/11 06:14 PM Re: One Time Reg E Disclosure LawAnd Order
dickr Offline
Gold Star
dickr
Joined: Feb 2010
Posts: 356
Middlesex Cty NJ
No - see Staff Commentary 205.7(a)-3:

"If a consumer opens a new account permitting EFTs at a financial institution, and the customer has already received Regulation E disclosures for another account at that financial institution, the financial institution need only disclose terms and conditions that differ from those previously given."

We use DepositPro, which is set up to print the current Reg E disclosures on all new accounts - CSRs can't change the disclosures. Who would be responsible for ensuring that the disclosures are given out when needed?
Last edited by dickr; 06/03/11 06:14 PM.
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#1560556 - 06/03/11 07:12 PM Re: One Time Reg E Disclosure dickr
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
If the customer wants wants a new service, there is a "close proximity rule". From Reg E commentary 205.7 comment 1

On the other hand, if an agreement for EFT services to be provided by an account-holding institution is directly between the consumer and the account-holding institution, disclosures must be given in close proximity to the event requiring disclosure, for example, when the consumer contracts for a new service.
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