Internet Banking: Reg E Disclosure Requirements

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Question:

What are the Reg E disclosure requirements for new Internet Banking clients? Do you need to re-disclose and if so can you do this electronically?

Answer:

The term "Internet Banking" has no standard meaning. In order to determine whether and how Reg E applies, you must conclude that a new EFT service is being initiated as a part of your client agreement. New transfer devices require additional disclosures. In order to provide them electronically, you must follow the e-delivery rules in Section 205.17.

First published on BankersOnline.com 7/21/03