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We are getting apply pay and google pay which enables a person to add their debit card info to their wallet on their iphone for example, and pay with their phone rather than their card. Also, this enalbes a person to pay another person directly, to move funds from person to person. Are these services required to be included, listed as types of EFTA transfers in our Reg E new account disclosure?
Good afternoon:
The answer to both questions is yes. In June 2021, The CFPB clarified, defined, and explained that the terms and requirements of the EFTA including:
1. Which consumers are protected,
2. Which transfer circumstances are covered, and
3. Who is obligated to follow the Act.Additionally, the CFPB clarified whether a P2P payment app qualifies as a financial institution and whether P2P transfers are covered by the EFTA.
The Bureau’s statement confirmed that:
1. P2P payment app companies fall into the official definition of a financial institution under the EFTA, and
2. P2P payments are specifically included as covered transactions under the Act.I hope this helps,
Kimberly
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