Answer:
Certain telephone-initiated transfers are exempted from the definition of EFT under section 205.3(c)(6). Specifically, if your VRU agreement doesn't anticipate that the service will be used for bill payment or for recurring payments, the VRU transfers would not be considered EFTs.
Internet banking transactions, however, are likely to be considered EFTs. For example, any transfer between accounts that is individually authorized by your consumer customer (for example, an individual transfer from a consumer's savings account to her checking account) will be an EFT.
Bill payments from a consumer's account initiated through your internet banking site will be considered EFTs subject to Reg E, unless your bill payment service makes some payments by check drawn on the consumer's account and you disclose to the consumer which payments will be made in that way. Payments made by that method will not be EFTs under the regulation. Transactions that don't meet the regulation's definition of EFT will not trigger a monthly statement requirement
First published on BankersOnline.com 12/11/06
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