ARLINGTON, Va.—Seeking guidance on Regulation E disclosures?
On a yearly basis, the NCUA identifies areas related to consumer compliance to be reviewed during exams. Regulation E has remained one of these items since 2018 and was included in the NCUA's recently released 2020 supervisory priorities. The latest Regulation E focuses include initial disclosures and error resolution.
NAFCU Senior Regulatory Compliance Counsel Jennifer Aguilar has highlighted the initial disclosure requirements provided in Section 1005.7(b), which include:
- Summary of the member’s liability for unauthorized electronic fund transfers (EFTs) and contact information to report them
- Notice describing the credit union’s error resolution responsibilities
- Types of EFTs the member may make and any limitations on the frequency or dollar amount
- Fees imposed for EFTs
- Summary of the member’s right to receipts, periodic statements and preauthorized transfer notices
- Summary of the member’s right to and procedures for stopping payment of a preauthorized EFT
“While most of these disclosures are rather straightforward, the disclosures regarding fees and the types of EFTs a member may make can cause some confusion for credit unions,” stated Aguilar.
Aguilar addressed two key components of initial disclosures under Reg E.
“Credit unions anticipating exams this year may find it useful to review their initial disclosures to ensure all required information is disclosed properly,” said Aguilar.