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Does Reg GG Apply to All Commercial Customers?

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Question: 
I am reviewing Regulation GG and am getting conflicting information. In recent training they said Reg GG applies to all commercial customers, for both loans and deposit accounts. But when I read the regulation and my other resources, it does not indicate both nor does it say only deposits. What is the correct answer, does it apply to all commercial customers, regardless if for a loan or a deposit account? I believe it applies to all commercial customers, regardless if deposit or loan. If that is true, where would you recommend the notice be on loan documents? For deposits, we have it in the Terms and Conditions. But I think for loans, we need a separate disclosure. What are your thoughts?
Answer: 

Not sure how having a loan would make them participants in any of the following designated payment systems.

Sec. 233.3 - Designated payment systems.

The following payment systems could be used by participants in connection with, or to facilitate, a restricted transaction:

(a) Automated clearing house systems;

(b) Card systems;

(c) Check collection systems;

(d) Money transmitting businesses solely to the extent they

(1) Engage in the transmission of funds, which does not include check cashing, currency exchange, or the issuance or redemption of money orders, travelers' checks, and other similar instruments; and

(2) Permit customers to initiate transmission of funds transactions remotely from a location other than a physical office of the money transmitting business; and

(e) Wire transfer systems.

First published on 12/16/2018

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