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In Response To:
Thread Starter: David Dickinson
Title: Re: Reg E Disclosure

I can tell you based on experience, that the wording Adam bolded (and colored) is very subjective. I recommend providing a new EFT disclosure EVERY TIME someone signs up for a new EFT service. Don't rely up on the "Close proximity" wording as it is too difficult to argue with an examiner that may have a different opinion.