07/30/2007
In what section of Reg E does it state that it is a violation for a bank to mandate a certain bank or their own bank to be used for employee payroll direct deposit?
06/25/2007
I am wondering if anyone has any knowledge of what the generally-accepted definition of "substantially regular intervals" is in terms of preauthorized EFTs under Reg E - is it at least every 60 days as is mentioned in 205.10(a)(1)?
04/16/2007
For an account which electronic fund transfers can be made, may the bank send a notice each time with the date, amount, source and account number and not the other information that would be on the monthly statement as opening and closing balance in place of a periodic statement for each monthly cycle in which an electronic fund transfer has occurred? In particular, on a savings account that is normally sent a quarterly statement when no EFT activity has occurred, will the notice mentioned above suffice for a direct deposit to the account in place of the monthly statement?
02/12/2007
I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
07/18/2005
We have a business account that's an LLC. The partners on this account would like to electronically debit this account to credit their personal accounts (also held at the bank)? Would you agree that this transaction should be electronic and if so, what documentation should we require? If the answer is to the contrary, then should we require that the customer write a check out of the business account and deposit to the personal accounts?
07/04/2005
We received a levy on a customer who did not have a deposit account with us. However, during the course of our investigation, we learned that his direct deposit for his payroll was going into his wife's account (which is a solo account). I know that Subsection 4.1.4 of the ACH rules allows us to post based on account number alone, but what is our obligation, if any, when we discover there is a discrepancy. Are we required to contact the customer to add the husband to the account? If so, do we return the credit if the change is not made? I have not been able to find a return reason code that fits this scenario.
10/04/2004
I am conducting an internal audit for a financial institution on Reg E - Electronic Fund Transfer Act. In 205.10(e)(2), it states that no financial institution or other person may require a consumer to establish an account for receipt of electronic fund transfers with a particular institution, as a condition of employment or receipt of a government benefit. I interpreted this that a financial institution cannot require a new employee to establish an account in order to receive a paycheck. Is my interpretation correct?
04/05/2004
We are looking at offering a stored value card that will allow our business customers to direct deposit payroll to this card, in a master account, rather than issuing a check or direct depositing to an individual's account. The business issues the card to the employee and they use the card just like a debit card. What disclosures are needed for this product and would these be issued to the business only, since they are our customer, or would it need to be issued to the business and each employee that receives a card?
03/01/2004
Our bank has several Christmas Club accounts that accept payroll deduction direct deposit credits from one of our significant business customers. Many of their employees have no other deposit relationship with our bank. Do we have to issue a statement on these club accounts under Regulation E?
05/12/2003
E-Checks Triple; Financial EDI Up 27 Percent