IBA Compliance Connection

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Is there any requirement that we must provide a receipt to customers for deposits — whether made in-person, through the night drop, or through the mail? I am not aware of any federal requirement. Is there a state law that addresses this subject?

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No, we are not aware of an Illinois law that requires financial institutions to issue receipts for deposits. However, Regulation E does require financial institutions to make receipts available for certain electronic deposits. If a consumer initiates a deposit of over $15 by an electronic fund transfer initiated at an electronic terminal, Regulation E would require a receipt. Covered electronic fund transfers would include deposits of cash and checks initiated by your customers (but would not include ATM deposits initiated by non-customers).

For resources related to our guidance, please see:

  • Regulation E, 12 CFR 1005.9(a) (“Except as provided in paragraph (e) of this section, a financial institution shall make a receipt available to a consumer at the time the consumer initiates an electronic fund transfer at an electronic terminal. The receipt shall set forth the following information, as applicable: . . .”)
  • Regulation E, 12 CFR 1005.9(e) (“A financial institution is not subject to the requirement to make available a receipt under paragraph (a) of this section if the amount of the transfer is $15 or less.”)
  • Regulation E, 12 CFR 1005.2(h) (“‘Electronic terminal’ means an electronic device, other than a telephone operated by a consumer, through which a consumer may initiate an electronic fund transfer. The term includes, but is not limited to, point-of-sale terminals, automated teller machines (ATMs), and cash dispensing machines.”)
  • Regulation E, 12 CFR 1005.3(b)(1) (“The term ‘electronic fund transfer’ means any transfer of funds that is initiated through an electronic terminal . . . . The term includes, but is not limited to: (i) Point-of-sale transfers; (ii) Automated teller machine transfers; (iii) Direct deposits or withdrawals of funds; . . . .”
  • Official Commentary, Regulation E, 12 CFR 1005, Paragraph 3(b)(1), Comment 1 (“Fund transfers covered. The term ‘electronic fund transfer’ includes: (i) A deposit made at an ATM or other electronic terminal (including a deposit in cash or by check) provided a specific agreement exists between the financial institution and the consumer for EFTs to or from the account to which the deposit is made. . . .”)