[TheBank]

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?

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[Kimberly Boatwright, CAMS, CRCM]

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

• This reply was modified 3 years ago by Brent V.

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