Answer by David Dickinson: Section 205.9(b) of Reg E requires monthly periodic statements anytime an account has an electronic funds transfer. If the account doesn't have an e-transfer, but could, you must send quarterly statements.
Answer by John Burnett: Regulation E's quarterly statement requirement applies to consumer accounts the owners of which have requested EFT access (an access card) or have signed up for an EFT service (of which the bank is or should be aware. So if the consumer has simply opened a savings account, for example, the Regulation E statement requirement would not apply, even though the account could be accessed via EFT. However, as soon as the same customer signs up for EFT access or when the bank receives an EFT that the customer signed up for with a third party (SSA direct deposit, for example), the statement requirement of Regulation E kicks in, and will require quarterly or monthly statements, depending on the nature and frequency of the EFTs.
Banks that aren't set up to detect accounts receiving a first EFT should consider setting consumer accounts up with statements to be issued at least quarterly.
First published on BankersOnline.com 1/16/12