Electronic Funds Transfer Act (Regulation E)
Overview
The Electronic Funds Transfer Act (EFTA) and Regulation E (12CFR205) set forth rights, liabilities and responsibilities of participants in electronic funds transfer systems. The regulation requires that all consumer customers be provided a disclosure statement of liability regarding electronic funds transfers before the transfer is made to or from their accounts; and that any preauthorized transfer from a consumer's account be authorized by the consumer in writing.
Policy
It is and shall be the policy of The Park Avenue Bank ("the Bank") not to accept or honor any electronic transfer to or from the account of a consumer customer before a copy of the Bank's electronic-funds-transfer disclosure statements has been delivered to the customer. Further, the Bank will not accept or honor any ACH debit to a consumer customer account unless the customer has authorized the debit in writing to the Bank.
Internal Controls & Procedures
Account Officers provide initial disclosures when customers request, in writing, authorization for electronic services. Disclosures provide information regarding the types of transfers available, rights and responsibilities of the consumer and the Bank and descriptions of error resolution procedures.
Monthly periodic statements are provided to consumers whose accounts have electronic generated transfers. Periodic statements include the amount, date of transfer, type of transfer, the mane of the third party payee or payer, the account number, beginning and ending balances, and the prescribed "direct inquires to" notice which includes the Banks telephone number. In addition the Error Resolution Notice is included on each statement.
If a change is implemented to EFT services, and that change would adversely affect customers, a notice is provided within 21 days prior to the effective date such change. If changes are required in order to maintain the integrity of security measures, a notice is provided within 30 days of the change.
The Account Officer is responsible for handling all inquires regarding unauthorized or disputed EFT to or from an account. A log is maintained in Operations to record the date, type of dispute presented, date of provisional crediting, and the date of resolution.
A customers oral request to stop a preauthorized transfer is honored, provided it is received at least 1 day before the scheduled transfer. Customers are then required to provide written "stop Payment" authorization within 14 days of the oral request.
