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Can you avoid listing transfer limitations in Reg E disclosures?

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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?

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 1/20/03

First published on 01/20/2003

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Filed under compliance as: 
Filed under security as: 

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