Reg E Type of Transfer/Type of Account

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Question:

Under Regulation E, section 1005.9(b), Banks are required to include the type of transfer and the type of account to or from which the transfer was made. The commentary doesn't specify how you disclose the type of account under this section (however, it does specify how to disclose this for terminal receipts under 9(a)). So, my question is, is it OK that our periodic statements just state "transfer from account XXXX" instead of specifying the account type or should it be stating transfer from checking/savings?

Answer:

Technically, the rule calls for describing the account type (not the account number), however, it's my personal opinion that providing the account number (or the truncated acct no) gives the consumer more specific info than required, and should be OK. I have never heard of a bank being dinged for including the [truncated] account number in lieu of account type.

So much has changed in the industry regarding EFT processing and statement rendering since Reg E was issued, and nothing has been done to make section 9 a little more workable for the industry and its consumer customers. It's really pathetic in that regard.