02/12/2007
I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
02/05/2007
What are the major changes that financial institutions need to make in order to be Reg E compliant as of January 1st?
01/29/2007
What are the major changes that financial institutions need to make in order to be Reg E compliant as of January 1st?
05/15/2006
For payroll confidentiality reasons, the FI where I work requires that all employees open a checking account at another institution for direct deposit of payroll. Is this a violation of Reg E relating to employment or government benefits which states. "No financial institution or other person may require a consumer to establish an account for receipt of electronic fund transfers with a particular institution as a condition of employment or receipt of a government benefit? As for as I know this issue has never been raised by any examiners.
01/30/2006
If a customer requests not to receive a monthly statement because he/she is able to view the information from our online banking system, is there a compliance issue, keeping in mind that we will still generate the DDA/Sav statement monthly and send it to our cold storage system?
04/25/2005
Required disclosures for new accounts
by Mary Beth Guard and John Burnett
Guru BIOS
01/24/2005
11/15/2004
This is a Regulation D question regarding savings accounts. We are looking at moving the balances of all savings accounts that have ACH debits currently set up, as well as all accounts that have an ATM or debit card, into a separate general ledger and classifying those accounts as "Transaction Accounts" for call report purposes. These accounts would not be closed or transferred to another type of account. This would leave the savings accounts as they are now. This would be an internal move only of the balances to a transaction account that the customer would not be aware of. The accounts would continue to earn interest and the customer would continue to pay the bank's excessive W/D fees. Would this eliminate the necessity to notify customers of limitation requirements on existing accounts? Could this make monitoring of any of the savings accounts possibly unnecessary? Could you continue to pay interest on this type of account? Or would this be considered a total violation of Reg. D?
04/26/2004
11/03/2003
I viewed a Guru Q and A on the topic of "When to give the Reg E Disclosure," answered by Andy Zavoina. If possible, I would like additional comment on the issue of redisclosing to an existing customer that subsequently requests an access device and/or new EFT service. For example, the customer receives an EFT disclosure at account opening. One year later, the customer requests a debit card. The Commentary [205.7(a)(4)] states that redisclosure is required if the terms and conditions differ from the initial disclosure provided. If the terms and conditions have not changed from the initial disclosure, and the disclosure covered all EFT services offered, does the reg REQUIRE redisclosure? I certainly concur that to redisclose in the above example would be prudent on a riskbased standpoint, but is it required?