Legal Seminar, Chicago, IL

Electronic Fund Transfers

Scope of EFTA

 “Electronic fund transfer” excludes: “any transfer of funds, other than those processed by automated clearinghouse, made by a financial institution on behalf of a consumer by means of a service that transfers funds held at either Federal Reserve banks or other depository institutions and which is not designed primarily to transfer funds on behalf of a consumer . . . .” 15 U.S.C. § 1693a(7)(B)  Remittance transfers are treated differently—Section 919 of Dodd-Frank Act subjected them to Regulation E