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Additional Reg E Disclosure for New Electronic?

Answered by: 

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

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 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 5/13/13.

First published on 05/13/2013

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