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Review of Regulation E - Electronic Fund Transfers, Part 2 Disclosures

NCJ Number
83162
Author(s)
J C Wood
Date Published
Unknown
Length
0 pages
Annotation
Disclosure requirements of Regulation E regarding electronic fund transfers are summarized in terms of format, content, and financial institution liability.
Abstract
Three types of disclosures are required: initial, periodic, and change-in-terms disclosures. The disclosures must be formulated in writing and be readily understandable to consumers. The regulation provides model disclosure clauses that a financial institution may choose to utilize to be protected from civil and criminal liability. Initial disclosures must contain 10 statements: a summary of consumer liability for unauthorized use of electronic transfers; a telephone and address for notifying the loss of a terminal access device; institutional business days; types of transfers, including amount and frequency, that consumers may initiate; fees; documentation; stop payment conditions, the financial institutions liability; third parties with access to information on consumer accounts; and an error resolution notice. Periodic disclosure requirements vary in terms of both content and timing. Change-in-terms disclosures must be made in writing 21 days in advance of the date of effectiveness. Examiners are cautioned to review disclosure forms and check their content to determine if an institution has imposed changes that were duly disclosed.