We currently have e-statements available for our e-banking customers and will be adding e-bills. Any e-banking customers that have e-statement and a loan account within their profile, will be converted to an e-bill for these loans. We will continue to send both the e-bill and the paper bill for a two to three month time period. There is no way to have these customers agree or accept a revised agreement without shutting off all e-statements and have them agree again, which is not a good option from a customer service perspective. Will we be OK if we send an email communication to all e-banking customers of the pending change and have a message printed on the loan bills alerting customers to the pending change? e-statement customers agreed to receive all disclosures and statements electronically when they initially signed up for e-statements.
Am I correct in saying that Reg E does not apply to business check cards?
I work for an insurance company and we are about to begin offering EFT for insurance payments. As an insurance company are we bound to Reg E disclosures on our notices?
When opening an account on the internet, what disclosures should be given to the applicant at time of application? This would be for checking, money market and CDs only.
Our bank is considering converting the ATM cards connected to the checking accounts of current customers into Visa debit/check cards. Would this be considered a substitution or renewal of a solicited card or must we follow the rules for an unsolicited card?
Our bank has several Christmas Club accounts that accept payroll deduction direct deposit credits from one of our significant business customers. Many of their employees have no other deposit relationship with our bank. Do we have to issue a statement on these club accounts under Regulation E?
On our Deposit Accounts web page, we discuss the types of accounts we offer. An account cannot be opened on our web site. Do we need to place our Funds Availability Disclosure on the page?
What is the difference between "pre-paid debit cards" and "stored value cards"? Are there any regulatory issues with offering them (other than EFT Error resolution?) and are there any difference in offering one over the other?
Can we offer debit cards to savings accounts customers? We would assume they would fall under Reg D. We are considering doing away with ATM cards
The American Bankers Association and the American Bar Association recently held their 14th annual Money Laundering Enforcement Seminar.