Research · 6 min read
What a Receipt for an Electronic Payment Has to Show
The federal documentation rule names six items for a terminal receipt and a longer list for the periodic statement. It binds the financial institution, which is why a seller's confirmation email is a different document with different contents.
Key takeaways
- Regulation E's documentation duties fall on the financial institution, not on the seller, and say nothing about what was purchased.
- A terminal receipt must show amount, date, transfer and account type, an identifying number or code of no more than four characters, the terminal location in a specified form, and the name of any third party.
- No receipt is required where the transfer is fifteen dollars or less.
- The periodic statement adds the account number, fees assessed, opening and closing balances, and the address and telephone number for inquiries and error notices.
- A transfer not documented as required is itself an error under the error resolution section, and a request for the required documentation counts as a notice of error.
- Initial disclosures are due when the consumer contracts for the service or before the first transfer, and a service added later with different terms requires its own disclosures.
Answer first: the rule binds the institution, not the seller
Regulation E states that a financial institution shall make a receipt available to a consumer at the time the consumer initiates an electronic fund transfer at an electronic terminal, and then lists what the receipt must set forth.
Every duty in the section falls on the financial institution. Nothing in it requires a seller to produce a document, and nothing in it specifies what a seller's own invoice or order confirmation must contain. That is the single most common misreading of this rule, and it matters for a purchase where the money moves electronically but the description of what was bought lives only on the seller's page.
The section has two halves. One is the terminal receipt, produced at the moment of a transfer initiated at an electronic terminal. The other is the periodic statement, produced on a cycle, covering an account to or from which electronic fund transfers can be made.
There is a floor under the receipt requirement. A financial institution is not subject to the requirement to make a receipt available if the amount of the transfer is fifteen dollars or less.
The six items on a terminal receipt
The regulation lists them as applicable. The amount of the transfer — and a transaction fee may be included in that amount, provided the amount of the fee is disclosed on the receipt and displayed on or at the terminal.
The date the consumer initiates the transfer. The type of transfer, and the type of account to or from which funds are transferred, with the account type omissible where the access device can reach only one account at that terminal.
An identification: a number or code identifying the consumer's account or accounts, or the access device used. The regulation caps that at what is necessary — the number or code need not exceed four digits or letters to comply.
The terminal location, or an identification such as a code or terminal number. Where the location is disclosed, and except in limited circumstances where all terminals are in the same city or state, it must include the city and state or foreign country, plus one of three things: the street address, a generally accepted name for the specific location, or the name of the owner or operator of the terminal if other than the account-holding institution.
And the name of any third party to or from whom funds are transferred.
Read that list against what a consumer usually wants to know about a health purchase, and the gap is obvious. There is no line for what was bought, no line for a quantity, no line for a period covered, and no line for a price per unit. The receipt is a record of a money movement, not a description of a transaction.
What the periodic statement has to carry
For an account to or from which electronic fund transfers can be made, a financial institution shall send a periodic statement for each monthly cycle in which a transfer has occurred, and shall send one at least quarterly if no transfer has occurred.
For each transfer during the cycle, the statement must show the amount; the date the transfer was credited or debited to the account; the type of transfer and type of account; the terminal location for a transfer the consumer initiated at an electronic terminal, other than a deposit of cash or a paper instrument; and the name of any third party to or from whom funds were transferred.
Beyond the transaction lines, the statement must show the account number; the amount of any fees assessed against the account during the period for electronic fund transfers, the right to make transfers, or account maintenance; and the balance in the account at the beginning and at the close of the statement period.
It must show the address and telephone number to be used for inquiries or notice of errors, preceded by the words Direct inquiries to or similar language. Where the institution uses the telephone-notice option for preauthorized credits, the statement must also carry a telephone number the consumer may call to find out whether preauthorized transfers to the account have occurred.
The section provides narrow exceptions. For accounts accessible only by preauthorized transfers to the account, a passbook account needs no periodic statement if the institution updates the passbook on presentation or enters the amount and date of each transfer on a separate document; other such accounts get a statement at least quarterly. Where a consumer initiates a transfer between two of the consumer's own accounts at the same institution, documenting it on one of the two statements satisfies the requirement.
Why the statement's third-party name is the useful field
Both the receipt list and the statement list include the name of any third party to or from whom funds are transferred. On a statement that is often the only field connecting a debit to the entity that took it.
That matters where a brand name and the legal entity that bills are different things, which is common in remote care. The statement carries the name the institution has, and the institution has whatever the payment system carried.
The section also supplies the failure mode. A financial institution's failure to provide a terminal receipt or to document a transfer on a periodic statement does not violate the part where the transfer was not initiated within a state, provided the institution treats an inquiry for clarification or documentation as a notice of error under the error resolution section.
That last clause connects the documentation rules to the dispute machinery. Under the error resolution section, a transfer not identified in accordance with the documentation rules is itself an error, and a consumer's request for documentation required by those rules is a notice of error. Documentation and dispute are wired together rather than being separate systems.
The disclosures owed before the first transfer
The documentation rules are only half the record a consumer is entitled to. Regulation E requires a set of initial disclosures at the time a consumer contracts for an electronic fund transfer service, or before the first electronic fund transfer involving the account is made.
The list runs to eleven items. A summary of the consumer's liability for unauthorized transfers. The telephone number and address of the person or office to be notified when the consumer believes an unauthorized transfer has been or may be made. The institution's business days — a definition that decides how every other deadline in the part is counted.
The types of transfers the consumer may make and any limitations on frequency and dollar amount, with the qualification that details of the limitations need not be disclosed where confidentiality is essential to maintain the security of the system.
Any fees imposed for electronic fund transfers or for the right to make transfers. A summary of the right to receipts and periodic statements and of the notices regarding preauthorized transfers. A summary of the right to stop payment of a preauthorized transfer and the procedure for placing such an order. A summary of the institution's liability for failure to make or to stop certain transfers.
The circumstances under which, in the ordinary course of business, the institution may provide information concerning the account to third parties. An error resolution notice substantially similar to the model form in the regulation's appendix. And a notice that a fee may be imposed by an automated teller machine operator, and by any network used to complete the transaction.
The section closes with a rule about additions. If an electronic fund transfer service is added to an account and is subject to terms and conditions different from those described in the initial disclosures, disclosures for the new service are required. A service bolted on later does not inherit the old disclosure.
Sources
- 12 CFR 1005.9, “Receipts at electronic terminals; periodic statements” (Regulation E)The duty to make a receipt available at the time a transfer is initiated at an electronic terminal and the six items it must set forth, including the transaction-fee condition, the four-character identification limit and the terminal location alternatives; the monthly and quarterly periodic statement frequency; the five per-transfer items and the account number, fees, opening and closing balance, inquiry address and telephone number, and preauthorized-transfer telephone number; the passbook and intra-institutional exceptions; the foreign-initiated transfer provision that requires treating an inquiry as a notice of error; and the fifteen-dollar small-value receipt exception.
- 12 CFR 1005.7, “Initial disclosures” (Regulation E)The timing of initial disclosures at contracting or before the first transfer; the eleven content items including liability summary, notification contact, business days, types of transfers and limitations with the confidentiality qualification, fees, documentation summary, stop payment summary, institution liability summary, third-party information disclosure, the error resolution model form notice and the ATM operator and network fee notice; and the requirement of new disclosures where a service is added under different terms.
Frequently asked questions
Does this rule tell a seller what to put on an invoice?
No. Every duty in Regulation E's documentation section falls on the financial institution. It governs the receipt made available at an electronic terminal and the periodic statement for an account from which electronic fund transfers can be made. What a seller must put on its own invoice comes from other bodies of law that this rule does not address.
What has to appear on a terminal receipt?
The amount of the transfer, with a transaction fee includible only if the fee amount is disclosed on the receipt and displayed on or at the terminal; the date the consumer initiates the transfer; the type of transfer and type of account; a number or code identifying the account or access device, which need not exceed four digits or letters; the terminal location or an identifying code, with city and state plus a street address, a generally accepted name for the location, or the terminal owner or operator; and the name of any third party to or from whom funds are transferred.
Is there a minimum transfer size?
The section states that a financial institution is not subject to the requirement to make a receipt available if the amount of the transfer is fifteen dollars or less.
How often does a statement have to arrive?
For an account to or from which electronic fund transfers can be made, the institution must send a periodic statement for each monthly cycle in which a transfer occurred, and at least quarterly if no transfer occurred. Narrow exceptions apply to passbook accounts and to accounts accessible only by preauthorized transfers into them.
What does the statement have to show besides the transactions?
The account number; the amount of any fees assessed during the period for electronic fund transfers, the right to make transfers, or account maintenance; the balance at the beginning and close of the period; and the address and telephone number for inquiries or notice of errors, preceded by Direct inquiries to or similar language.
What is a consumer told before the first transfer?
The initial disclosures cover liability for unauthorized transfers, the contact point for reporting them, the institution's business days, the types of transfers and any limits, fees, the right to receipts and statements, the right to stop payment of a preauthorized transfer and how, the institution's own liability, the circumstances under which account information goes to third parties, an error resolution notice matching the model form, and notice that an ATM operator and network may impose fees.