Amending Our Reg E Notices & Disclosures

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Question:

With the small dollar receipt exception amendment to Reg E effective 8/6/07, do we need to amend the terminal transfer paragraph in the initial Reg E disclosure and provide a change in terms notice to our existing customers? I know the final rule did not provide any new model text, but I saw an article on Compliance Headquarters that raises this question.

Answer:

I recommend adding a mention of the new exception to your new account disclosures, although it's not clear that it's required. As for existing customers, you can cast your Reg E notice as a simple informational factoid. Beginning August 6, 2007, some terminals may not provide a receipt for ATM or POS transactions of $15 or less.

First published on BankersOnline.com 8/06/07