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A2A Statement Information

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We are in the process of adding external account transfer capability (A2A)to our Internet banking service. Our vendor indicates that these transactions will show on our statements as Internet-initiated transactions and all transactions will display our own bank name. It is my contention that the statement should indicate the name of the other institution and I believe Reg E 205.9 (b)(1)(v) supports this. Of course, since it would only be logical to have the name of the other F.I. on the statement, it probably isn't required.

If the account is a consumer account, Regulation E's section 205.9(b)(1)(v) would apply. If the transfer is to another account of the same consumer at another institution, one could argue that no third party is involved, I suppose. However, if the transfer is to a business or another consumer, whether within the same bank or at another bank, the name of the business or consumer (not just an account number) must be shown. See the Official Staff Interpretations to 205.9(b)(1)(v).

First published on 8/31/09

First published on 08/31/2009

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