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List Account # on Periodic Statements? (Reg E)

Question: 
Does Reg E require us to list the full account number on the periodic statements, specifically those that are e-statements?
Answer: 

Answer by Randy Carey: 1005.9(b) Periodic statements. For an account to or from which electronic fund transfers can be made, a financial institution shall send a periodic statement for each monthly cycle in which an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred. The statement shall set forth the following information, as applicable:

(2) Account number. The number of the account.

Answer: 

Answer by John Burnett: Several years ago, the Fed amended Regulation E to permit the truncation to as few as four digits of the account number or card number that must appear on electronic terminal receipts. That was done to address the problem of cardholders who carelessly tossed away ATM and POS receipts that, at the time, listed full account or card numbers. When it did that, the Fed could have permitted the truncation of account numbers on statements, but didn't do so. I imagine that there was not the same level of concern about carelessly discarded statements.

So we're left with the paradox that a bank can legally truncate an account number on a statement if there are no consumer EFTs subject to Regulation E being reported on the statement, but there's no regulatory support for doing so if it's a consumer statement with Regulation E EFTs.

That said, the regulation does not explicitly say that the account number must not be truncated; it says the number of the account must be on the statement. The purpose of that requirement is, of course, to tell the consumer which of his or her accounts is affected by the EFTs reported on the statement. One could argue that a truncated number would identify the account sufficiently.

Just to offer the other side of the argument, don't forget that many transaction account statements include images of the customer's paid checks. Unless you are able to mask the account number appearing on those images, truncating it elsewhere on the such statements seems to be a wasted effort.

First published on BankersOnline.com 10/29/12

First published on 10/29/2012

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