Can you avoid listing transfer limitations in Reg E disclosures?

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Question:

The bank would like to disclose "security reasons" as the reason not to list transfer limitations in its Reg E disclosures. I see model language (For security reasons, there are limits on the number of transfers you can make using our [terminals] [telephone billpayment service] [pointofsale transfer service].) for the "frequency" of transfers but not for the "dollar amount" of transfers. Can you use similar language for the dollar amount of transfers?

Answer:

Yes, you may use similar disclosures concerning the dollar limits on transfers or withdrawals. Be cautious here customers can become very unhappy if you deny a POS transaction solely because of these security concerns, and you haven't given them guidance on what their limits might be.

First published on BankersOnline.com 1/20/03