Electronic bill payment and presentment (EBPP) services are a core component of many financial institutions' on-line banking offerings. This paper discusses the laws (state and federal), regulations, and regulatory guidance generally applicable to EBPP services offered through financial institutions. Particular emphasis is given to (i) the Electronic Fund Transfer Act and Regulation E (including provisions relevant to dispute resolution, liability for unauthorized transactions, and electronic disclosure) and (ii) regulatory guidance with respect to outsourcing arrangements in connection with the offering of EBPP services. The paper talks about and provides an overview of the law and regulatory guidance as it is today - it does not advocate or recommend any specific changes at this time.
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Article provided by Federal Reserve Bank of Chicago in its journal Emerging Issues.
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