Since Reg E is silent on expirations of preauthorized electronic stop pays, it is assumed then that it essentially doesn't expire, right?

My bank is wanting to add an area to the stop payment forms that the customer can fill in when they want the stop payment to expire. This would eliminate the need for the bank to track on this forever. However, I am concerned with examiners possibly seeing this as "steering" the customer into making a decision that benefits the bank and not the consumer. Would the bank be able to ask the customer to provide such information and then use that as the expiration date?

Has anyone else run into this? If so, what steps did you take?

In our case, we fill out the form, not the customer. I think that policy would eliminate the steering issue. Perhaps another method would be to give them a pair of check boxes: one saying that the stop pay doesn't expire and one that lets them specify an expiration date of 6 months or less. That way the choice is on the paper where it can be clearly seen by the customer and examiners.

Our form (ordered from EastPay) has three options for stop pays: "Stop Single Entry", "Stop Multiple Entries", and "Stop All Future ACH Debits Under a Specific Authorization". One of those three options gets checked for ACH items. In addition, if "Stop All Future..." is chosen, it requires the customer to initial a statement saying that they've contacted the company and revoked the authorization in accordance with Reg E.

We ask each customer how they want to apply the stop payment to their account. If a consumer chooses to "Stop All Future..." the stop pay simply goes on with no expiration date. We use the "Stop Single Entry" & "Stop Multiple Entries" options to satisfy more unique requests on consumer accounts, like only stopping a debit from a company once and then letting them resume, or only stopping payments for a specified time period of 6 months or less. If they want an expiration date of over 6 months, it gets put on as a "Stop All Future..." without an expiration date & the customer then informs us when they want it removed.

Of course, since Reg E doesn't apply to non-consumer accounts our policy for businesses is still a 6 month expiration for all written stop pay requests, unless renewed in writing.

Thank you tdogz! I appreciate your information.