Changing on-us check deposits to transfers

Regulation E can cause you some heartache here. Such a transfer would likely be viewed as subject to Regulation E, since it would be electronic and involve accounts of different persons. That would trigger statement disclosure problems, since you would need to disclose the name of the counterparty on each customer's statement (assuming we're dealing with consumers).

Also, if the check is drawn on an MMDA, you'd be changing the nature of the transaction from a third party check to a third party transfer. Your software would have to continue counting the transfer in the "3" bucket since it originated as a third party transfer by check.

First published on BankersOnline.com 9/20/04