Reg E Fee Disclosure Breakdowns

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Question:

Do return (chargeback) ACH transactions have to be broken down individually (online or on consumer statements) or can the multiple returns be sent back to the originating deposit system and on the customer statement as an aggregate (total of all returns) return amount?Does Reg E cover commercial accounts or only consumer?

Answer:

Last question first. Regulation E does not cover transactions in commercial accounts or the accounts themselves. It only covers transactions in accounts established primarily for personal, family, or household purposes (and the accounts themselves).

As to charged-back ACH items -- I am going to read between the lines and assume you're referring to ACH collection of charged-back checks. If that is the case, Reg. E will not affect how you post the ACH RCK transactions (since they are not subject to the regulation). However, any related fees imposed as penalties for the bounced checks are subject to Regulation E. These fees are not your fees, and you are not imposing them. So they are to you merely separate EFT transactions. Each must be described on the statement in conformity to Reg. E requirements, and that means each must appear separately.

First published on BankersOnline.com 06/7/04