Reg Z - Agreements for all open accounts

Posted By: Hi

Reg Z - Agreements for all open accounts - 01/20/10 07:42 PM

In regards to section 226.58(e)- Agreements for all open accounts: We are a small issuer so we are exempt from publishing agreements with the Board and on a website. Our credit card processing is handled off-site by a third-party. Our bank's website does not include access to credit card account information; however, the 3rd party provider maintains a website where are customers can access their account information.

Since we, the bank, do not maintain a website, are we allowed to follow the rules for issuers without interactive websites or do we need to ensure that our 3rd-party provider includes the ability for our credit card customers to request a copy of the agreement?
Posted By: terpsfan

Re: Reg Z - Agreements for all open accounts - 05/05/10 04:00 PM

bump