Reg E Disclosure on Bank's Web Site

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Question:

We do not open accounts online. The Reg E disclosure on our Bank's Web site covers the types of transfers that are allowed for Online Banking along with fees, documentation, Financial Institution's Liability, Confidentiality, Unauthorized Transfers, Error Resolution Notice, etc. (i.e., things we don't need), but this disclosure does not include other EFTs, such as check conversion. Is it required here? The Reg E disclosures provided to customers other than on the Web (new account, debit card application, etc.) do include that type of EFTs.

Answer:

Answer by David Dickinson: If you do not open accounts online, you do not need an EFT (Reg E) disclosure on the web. As long as customers receive an EFT disclosure when they open an account and when they sign up for new electronic services, you don't need to be concerned.

Answer:

Answer by Richard Insley: I would get rid of online disclosures that are not needed. If you continue to give the "official" Reg E disclosures in paper form, then the online material can only lead to trouble. Should examiners find contradictions between the two, you may be cited for providing confusing, inaccurate disclosures.

First published on BankersOnline.com 3/01/04