Compliance Question of the Week

Do transfers initiated through a mobile device require a receipt with the transaction?

No. Like transfers and bill payments that are initiated by the member through their online banking, transactions on mobile devices are considered analogous in function to a telephone.  These transactions are considered electronic funds transfers and are covered under Reg. E, but are not considered to be initiated at an electronic terminal such as an ATM or POS and do not require a receipt at the time of the transaction.

The transactions will need to be clearly identified on the periodic statement.   

Related Links:

12 CFR 1005.2 (h)

Reg E Official Staff Commentary

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance.