Reg E Receipt Requirement Changes

Why it’s important to tell your accountholders

On July 5, 2007, the Federal Reserve Board published a final rule amending Regulation E. Under the final rule—effective August 6, 2007—a consumer is no longer entitled to a receipt for an electronic fund transfer made at an electronic terminal if the amount of the transfer is $15 or less.

The Board did not provide updated model language for disclosing this amended receipt requirement. However, using the current model text may no longer provide a safe harbor because the existing model language suggests a consumer can get a receipt for any transfer. Whether a consumer in fact gets a receipt on any given transaction is out of your control—the retailer or service provider will make that decision. As a result, since a consumer may not be offered a receipt for all transactions, you should update your disclosure, and amend your contract with the consumer, to reflect that a consumer may not get a receipt for a small-dollar transaction.

Notifying your accountholders of this change could also prevent customer service issues down the road. Many consumers rely on receipts for recording-keeping. By informing consumers about the change, you’ll not only be putting your institution in a better position from a contractual standpoint, but you may also help reduce the number of customer service inquiries. Read more.

Recommended Action Steps

• Send a change notice to existing accountholders as soon as possible.
  
  
• Begin using a modified Reg E disclosure as soon as practical.
  
  
• Explain the changes to accountholders using the Wolters Kluwer Financial Services “Why didn’t I get a receipt” education brochure. This brochure provides a comprehensive overview of what accountholders can expect. It is available in two versions:
  
  
• Institutions who Offer Online Banking
• Institutions who do not Offer Online Banking