Answer:
Answer by David Dickinson:Yes. See the Reg E Staff Interpretations - Section 205.7(a)#1. It indicates a new Reg E disclosure must be provided "in close proximity to . . . . when a consumer contracts for a new service."
Answer:
Answer by Andy Zavoina:If it hasn't changed, I don't think there is a need to provide a duplicate disclosure if the consumer has had EFTs. I don't think you have to redisclose each time a defined service is used for the for the first time. Otherwise, I agree with David under the assumption that there was a long gap and there were no EFTs. That said, "close proximity" is not a defined term. I wouldn't want to go beyond six months here, max. I'd feel better at three. If you can make the disclosure electronically (E-SIGN) I would certainly promote doing it.
First published on BankersOnline.com 9/17/07
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