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Disclosures On Back of Card Carriers-Reg E

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Question: 
We currently provide the Reg. E disclosures on the back of our card carriers. All disclosures are provided at account opening but the disclosures on the card carriers were added as an extra step. Is this a common practice for other banks?
Answer: 

This was probably set up this way in case someone opened a deposit account, but didn't sign up for the debt card until two years later:

Official Interpretation

7(a) Timing of Disclosures

1. Early disclosures. Disclosures given by a financial institution earlier than the regulation requires (for example, when the consumer opens a checking account) need not be repeated when the consumer later enters into an agreement with a third party to initiate preauthorized transfers to or from the consumer's account, unless the terms and conditions differ from those that the institution previously disclosed. This interpretation also applies to any notice provided about one-time EFTs from a consumer's account initiated using information from the consumer's check. 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.

First published on 02/04/2018

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