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If we turn on the P2P service (which uses the debit card rails for funds transfer) are we required to give an updated Reg E disclosure? I think no because the debit card/mobile banking is the access point which has already been disclosed. But then I think what if we should have and we didn’t. Overthinking and need help!!
I agree – I do not think you would be required to provide a new disclosure unless there is something in the original disclosure that causes you concern or to believe you should re-disclose (which I assume there is not).
Thank you for responding! No there isn’t anything of concern, we have a tendency to overthink things and create more work than necessary.
Did you attend the Reg E seminar Susan Costonis did last week? If so, I can send your disclosure to her for review – email it to me at robin@mycomplianceresource.com. Thanks!
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