Reg. E Applicability Confusion

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Question:

In Reg. E, transfers initiated by telephone can be included and excluded from coverage based on some conditions. What are those conditions?

Answer:

If the telephone transfer is under a telephone bill-payment plan, or under another written plan that anticipates recurring or periodic transfers, it's subject to Regulation E. I'd include any VRU-based transfer system in this category.

If it's a transfer by telephone call handled by a "live" employee and not under a "plan," it's not subject to Regulation E.

First published on BankersOnline.com 4/19/04