I have been told that compliance with the Revisions to the Staff Commentary for Reg E regarding electronic check conversions, etc. has been delayed until Oct. 1, 2002. Can anyone confirm that and what source are you using?

The revisions in question were published March 16, 2001, at 66 FR 15187, and were effective 3/15/2001, with mandatory compliance by 1/1/2002. I have searched the Federal Register for anything published since then (on the topic), and find nothing.

So I need to turn your question around -- what is your source?

I checked all resources as I have several vendors that their disclosure forms already have that information in it. I checked all federal govenment resources as well and located no changes on the effective date. Please respond on where you saw this change. Thank you.

Our platform vendor is the one telling me the date changed to October 2002 - our deposit documents have not been updated!

Ask them for their source. This is from the Reg.

12 CFR Section 205.3--Coverage [OFFICIAL STAFF COMMENTARY]
The following text of Supplement I, Section 205.3(b) paragraphs v and vi are added effective March 15, 2001.
Compliance is optional until January 1, 2002. (66 FR 15187, March 16, 2001).

v. A transfer via ACH where a consumer has provided a check to enable the merchant or other payee to capture the routing, account, and serial numbers to initiate the transfer, whether the check is blank, partially completed, or fully completed and signed; whether the check is presented at POS or is mailed to a merchant or other payee or lockbox and later converted to an EFT; or whether the check is retained by the consumer, the merchant or other payee, or the payee’s financial institution.

This says it is covered. And your disclosures should describe what is covered. If they have more, it would be good to see.

Talked to my platform vendor late yesterday and the language has been added to the TIS section of our disclosures but not to Reg E. They are saying the FDIC is "recommending" but not yet requiring the language be added to Reg E. The vendor plans to have it added to Reg E by Oct. 1st. Now, I'm pondering the issue of whether or not existing customers MUST be notified - I've read other opinions in a related posting.

Would anyone be willing to share the language they have added to their Reg E disclosures?

I don't recall now what I put in ours. Since there is no template, you'll want to be thorough and accurate for what you do. Some prior discussion may get your disclosure authoring blood pumping.

Our platform forms vendor placed the re-presented check and the electronic check conversion disclosure language in our deposit account agreement and disclosure. I can share the language if the person asking sends their fax number. Thanks.