Answer:
If you do not have a contract with Zelle, then Zelle is acting as an electronic fund transfer service provider as defined in 1005.14. The answer to the question asked is, "Yes, it is a Reg E matter." However, it is a Reg E matter between Zelle and the customer. The bank's only responsibility is to provide periodic statements so the customer and Zelle can identify transactions that may be disputed.
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