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Reg. E Error Resolution Notice

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Question: 
We have the Regulation E Short error resolution notice on the reverse of our statement paper. We do not send an annual notice to our passbook account holders. Passbooks may receive a Direct deposit. Are we required to send a separate annual notice to these customers? Our auditors say we are. I thought passbooks were exempt from the periodic statement requirement and that the short Reg. E notice on the statement could be used in lieu of an annual notice.
Answer: 

Your auditors are correct. Because you don't send your passbook customers a statement, you cannot use the short-form error resolution notice to comply with the requirement. That leaves you with no alternative but to deliver the annual (long) form notice to all your passbook customers who receive EFTs.

First published on 04/18/2005

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