Reg E Initial Disclosure + Types of EFTs available

Posted By: NoJustNo

Reg E Initial Disclosure + Types of EFTs available - 07/24/20 09:55 PM

Reg. E wants you to disclose the "type of electronic fund transfers that the consumer may make..." and then provides no examples. How specific should we get here?

If the definition states of an EFT is: "The term “electronic fund transfer” means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account. The term includes, but is not limited to:(i) Point-of-sale transfers; (ii) Automated teller machine transfers; (iii) Direct deposits or withdrawals of funds; (iv) Transfers initiated by telephone; and (v) Transfers resulting from debit card transactions, whether or not initiated through an electronic terminal."

It would seem that each of the terms directly mentioned should be disclosed (if applicable) -- but what else are you including?

Internet banking? Mobile deposit? I just don't know how far to go....
Posted By: rlcarey

Re: Reg E Initial Disclosure + Types of EFTs available - 07/24/20 10:05 PM

Have you looked at Appendix A - Model A-2 Section (d)?

https://www.bankersonline.com/regulations/12-1005-appa#A2
Posted By: NoJustNo

Re: Reg E Initial Disclosure + Types of EFTs available - 08/17/20 06:47 PM

I have - but it seems that the appendix is very, very limited. I see some banks identify methods like telephone banking, bill pay, mobile baking, mobile check deposit, online banking, etc. ... and then specify the types of transactions. It's hard to know how far to go. For example, I can see the viewpoint of "bill pay" or "mobile check deposit" falling under "online banking."
Posted By: John Burnett

Re: Reg E Initial Disclosure + Types of EFTs available - 08/18/20 08:04 PM

"Mobile check deposit" is not an EFT.