Hi Everyone,

Question I'm hoping for some help on. We have an ACH authorization form that our bank uses to allow a borrower to authorize our bank to debit a borrower's account at another bank to pay the monthly payments due on their loan account at our bank.

I do not think that this ACH form would require the initial disclosure requirements found in 1005.7(b), but have not found anything definitive to support my position.

Would anyone be able to confirm that my gut feeling is correct and if so point me in the right direction?

Thank you!

Any responsibility for initial disclosures under 1005.7(b) is solely the responsibility of the financial institution holding the consumer's asset account. Not your institution that holds the loan. You are just required to get and maintain written authorization from the consumer under 1005.10(b).