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My bank's address and phone number is on the front of every statement page. Is this sufficient to comply with Regulation E, or must the bank include the contact information in the text of the notice?

Regulation E requires financial institutions to provide error resolution notices, including contact information. My bank's address and phone number is on the front of every statement page. Is this sufficient to comply with Regulation E, or must the bank include the contact information in the text of the notice, which appears on the back of my bank's statements?

It might be sufficient—the regulation is not clear—but the model form includes the contact information, and there is value in using the model forms because compliance is ensured. Section 1005.8(b) of the regulation requires banks to provide an error resolution notice that is “substantially similar” to the model form. Model Form A-3, for both the stand-alone error resolution notice and the periodic statement notice includes places to insert the bank’s telephone number and address.

The purpose of putting the bank’s contact information in the text of the notice is to make the complaint process easier for consumers by placing the contact information in close proximity to the error resolution rights information so they need not search for it elsewhere. In addition, many banks have a different address and phone number for Regulation E errors than for other types of inquiries. Even if the bank’s contact information is the same for both, there is still a risk that an examiner might claim the notice is not “substantially similar.” Thus, the safer approach is to include the contact information in the text of the notice. (December 2018)

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