No, you are not subject to Regulation E’s error resolution procedures in this case. Regulation E applies only to accounts that are subject to an agreement for EFT services between your institution and the consumer. Because you do not have an agreement for EFT services with the noncustomer, Regulation E’s error resolution procedures do not apply.

For resources related to our guidance, please see:

• Regulation E, Official Interpretations, 12 CFR 1005, Paragraph 3(a), Comment 1(i) (“The requirements of the regulation apply only to an account for which an agreement for EFT services to or from the account has been entered into between: i. The consumer and the financial institution (including an account for which an access device has been issued to the consumer, for example) . . .”)