Reg E New Account Disclosure Apple Pay & P2P

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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,

    • This reply was modified 2 years ago by Brent V.
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