Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#2281560 - 02/24/23 07:52 PM Online Banking - Reg. E Disclosures
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,337
Wisconsin
Are Reg. E disclosures required to be part of an online banking agreement? Or at the very least provided when someone signs up for online banking?

Return to Top
Operations Compliance
#2281580 - 02/25/23 08:51 AM Re: Online Banking - Reg. E Disclosures CSB98
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Some of it depends on what is included in your initial disclosure and when it was given.

Official Interpretation
7(a) Timing of Disclosures
1. Early disclosures. Disclosures given by a financial institution earlier than the regulation requires (for example, when the consumer opens a checking account) need not be repeated when the consumer later enters into an agreement with a third party to initiate preauthorized transfers to or from the consumer's account, unless the terms and conditions differ from those that the institution previously disclosed. This interpretation also applies to any notice provided about one-time EFTs from a consumer's account initiated using information from the consumer's check. 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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z, John Burnett