A to Z of Reg E

“Reg E hasn’t changed, so what’s to learn?” Although the regulation itself and the commentary haven’t changed, over the years interpretations of who is a financial institution, what is an error, and who has to investigate errors have. So has the use of EFTs — they’re up and that means more work for you. Plus, we routinely see Reg E violations and poor practices being cited in exams and that means the rules are not clearly understood. Now it’s risk management, and how confident your staff is in their application of the rules.

You must be familiar with Reg E from § 1005.01 all the way through § 1005.36. UDAAP penalties have been imposed because there was a disconnect between what was disclosed under Reg E and what was being done by financial institutions (yes, plural) on claims. A simple insertion of a FI requirement in a procedure meant the boilerplate disclosure was wrong! There are many hazards on the EFT path. This is why it’s good to take a breath and look at all of Reg E: disclosures, procedures, and most certainly, claims. This presentation will answer your questions in detail and dispel many of the urban myths that prevail in the world that is Reg E.