Additional Reg E Disclosure for New Electronic?

Answered by:

Question:

Does an additional regulation e disclosure have to be given to a member every time a new electronic service or device is added?

Answer:

Answer by Sonja Kriegsmann: The Commentary to Section 1005.7 of Reg E does not require a new disclosure when the consumer obtains a new service or account if the original Reg E disclosure provided to the consumer includes information regarding the new service or account, and that information has not changed. You can review the details of the Commentary.

Answer:

Answer by Randy Carey: However, the commentary does state that:

"On the other hand, if an agreement for EFT services to be provided by an account- holding institution is directly between the consumer and the account-holding institution, disclosures must be given in close proximity to the event requiring disclosure, for example, when the consumer contracts for a new service."

You will have to decide your bank's definition of "close proximity". Most bank routinely deliver a new EFT disclosure at the time of new access devices being granted, such as a debit card or internet banking.

First published on BankersOnline.com 5/13/13.