Reg E Policy Update

Regulation E Policy Update - 01/18/06

Bankpolicies.com is proud to announce the immediate availability of our revised Regulation E Policy Template product.

The revision to this product is in response to the Federal Reserve Press Release dated 12/30/05 which announced final amendments to Regulation E (Electronic Fund Transfer Act). The amendments clarify the responsibilities of parties involved in electronic check conversion transactions and require that consumers receive written notification in advance of these transactions.

The Board also released an interim final rule which provides that payroll card accounts established directly or indirectly by an employer on behalf of a consumer to which electronic fund transfers of the consumer's salary, wages, or other employee compensation are made on a recurring basis are accounts covered by Regulation E.

The mandatory compliance date for the final amendments is January 1, 2007. The interim final rule for payroll cards is July 1, 2007.

http://www.federalreserve.gov/BoardDocs/Press/bcreg/2005/20051230/default.htm

What's New

Topic 5 - Access Device. Formally included in the "Regulation E Requirements" section, this topic was expanded and made into a separate topic within the policy.

Topic 6 - Payroll Card Accounts. This new section was implemented based upon the interim final rule and contains the following subtopics:

General

Alternative to Periodic Statement Requirements

Initial Disclosure Requirements

Annual Error Resolution Notice Requirement

Limitations on Liability

Error Resolution

The following new form templates are now included with the purchase of the policy template product:

Regulation E Affidavit of Unauthorized EFT Activity (3 pages)*

Regulation Dispute Letters (2 pages)

Regulation E Dispute Resolution Log (1 page)

Regulation E Sample Error Resolution Notice on Periodic Statements (1 page)

Regulation E Sample Initial and Annual Error Resolution Notice (1 page)

Regulation E Sample Initial Disclosure (3 pages)

Regulation E Sample Payroll Card Account Disclosure (1 page)

*Supersedes our Affidavit of ATM/POS Activity and EFT Customer Complaint Form Template Products.

What's Revised

Topic 3 - Definitions. The definition of "Account" was modified and the definition of "Electronic Fund Transfer" refers to Section 4 which covers that subject in detail.

Topic 4 - Regulation E Requirements. This entire section was revised and expanded to include the following subtopics:

General

Electronic Fund Transfer

Electronic Fund Transfer Using Information from a Check

Collection of Service Fees via Electronic Fund Transfer

Topic 7 - Customer Disclosures. Slight changes were made to this section based upon the new guidance.

Topic 8 - Preauthorized Transfers. This section was enhanced to provide a more in-depth explanation of regulatory guidelines and staff commentary.

Topic 11 - Automated Teller Machine Disclosures. Subject matter under the "General" subtopic was revised based upon the final rule.

Topic 12 - Error Resolution. A new form template "Regulation E Affidavit of Unauthorized EFT Activity" was incorporated throughout this section, and various procedures were modified and responsibilities clarified.

Topic 16 - Provisional Credit and Transaction Reversal. The "Regulation E Dispute Letters" are now referenced in this section and procedures were modified and responsibilities clarified.

Ordering Information

This revised product is available to purchase from Bankpolicies.com for:

$250.00 - List Price

- or -

$100.00 - Update Price (applies only to clients who have previously purchased our Regulation E Policy Template product)

If you have ordered this product after 12/18/05 you are eligible to receive the Product Update at no charge.

Click here to place an order for this product. Clients who are eligible for our Legacy Rewards Volume Discount can apply their applicable discount level to the upgrade or list price (whichever applies).

NOTE: Refer to our Place an Order page for important information regarding payment terms and our return policy. Orders placed for Product Updates are only available directly through Bankpolicies.com.