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Guidelines on Bill Pay Feature for Online Banking

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Question: 
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.
Answer: 

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 BankersOnline.com 6/13/11

First published on 06/13/2011

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