Disclosures required for mobile banking.

We are implementing mobile banking and I was wondering if there are any disclosure that need to be given when the customer signs up it? Also, would it be alright if we just incorporated a mobile banking agreement in with our online banking agreement?

We are also in the implementation stage of mobile banking. I believe the Reg E disclosure may need to be updated to include the mobile banking as an access method and its use for transfers. From the other institutions in our area that have implemented mobile banking, it appears the customer enrolls for mobile banking once signed in to the online banking. I do not know if any additional disclosures are provided via the online banking site.

Do we need to indicate the type of balance we are disclosing, whether it is the current balance, available balance, etc.? We currently are not, only showing the balance amount (current bal).

I feel that we need to because in our case we are disclosing any debit transactions that have not cleared; therefore, not yet reflected in the balance amount....could be misleading to the customer. Any thoughts.

thanks,

Unless you are disclosing a balance that includes overdraft funds (from an account or LOC transfer or from the bank's overdraft service), you aren't required to use specific descriptions. I do, however, recommend providing the customer the information that he had use to figure out what the number means.

If you are disclosing a balance with overdraft funds you have some compliance problems. You need to adhere to the requirements of Reg DD §§ 230.11(b) and (c). With the possible exception of some smartphones, you may not be able to comply in a mobile application.

Thank You...the balance we are disclosing does not include overdraft funds.

That makes life a lot easier.