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We are discontinuing the service of permitting deposits at our ATMs. Do we need to update our Regulation E disclosures and resend, or can we simply notify customers of the change in a statement message? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We are discontinuing the service of permitting deposits at our ATMs. Do we need to update our Regulation E disclosures and resend, or can we simply notify customers of the change in a statement message?

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Yes, Regulation E requires you to deliver a change in terms notice to customers because you are removing one of the types of electronic fund transfer services that previously was available to your customers.

For resources related to our guidance, please see:

  • Regulation E, 12 CFR 1005.8(a)(1)(iii) (“A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition required to be disclosed under § 1005.7(b) of this part if the change would result in: . . . (iii) Fewer types of available electronic fund transfers . . . .”)
  • Official Interpretations, Regulation E, 12 CFR 1005, Paragraph 3(b)(1), Comment 1 (“The term ‘electronic fund transfer’ includes: (i) A deposit made at an ATM or other electronic termination (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.”)