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Guidelines on Bill Pay Feature for Online Banking

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The agreement we have customers sign when they enroll in our online banking product includes language regarding the Bill Pay feature. If a customer chooses not to use Bill Pay at that time but decides to take advantage of it at a later date, would they need to sign an additional document or disclosure? If it is not a requirement, would it be a best practice to have them sign something or provide them with a complimentary document that describes the Bill Pay features? Any help along with possible regulatory cites is very much appreciated.

Most Bill Pay programs are subject to Regulation E. If yours is, the regulation requires that disclosures relating to an electronic fund transfer service or feature be provided to a consumer "in close proximity" to the event requiring disclosure -- the signing up for the new service. See Regulation E, Supplement I (Official Staff Interpretations), Comment 7(a)-1.

First published on 6/13/11

First published on 06/13/2011

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