Last weekend I was out restocking the school supply closet in my home, which is really just a Rubbermaid bin, and I noticed that quite a few stores have made the switch from flamingos and floaties, to pens and pencils, and now, ghosts and goblins. I always get a bit melancholy around this time thanks to fond childhood memories of going to MEMCO for Halloween costumes. The excitement of all those little boxes on the shelves with the plastic windows through which one could see the mask that matched the costume inside the box- like a bunny rabbit, a princess, a superhero, or a witch. I rarely see boxed costumes with plastic masks nowadays, probably for good reason. I can’t be the only person that fell off a few porches and into bushes because I couldn’t see with the mask on. For a few Halloweens, one of my parents had to back track more than once to come find me because I got stuck in the bushes. Looking back though I’m not sure it was because of the mask. It was more likely due to my siblings and the neighbor kids in the group, full-on shoving me out of the way to get more candy. Good Times. Trick or Treat!
So, to mask or not mask? What I’m actually referring to is masking (hiding, truncating) numbers. What requirements are there regarding not displaying an account number? Well, Regulation E comes to mind.
For transaction receipts such as those from the ATM, the number can be masked so that only the last four digits or letters are provided on the receipt:
- “A number or code that identifies the consumer’s account or accounts, or the access device used to initiate the transfer. The number or code need not exceed four digits or letters to comply with the requirements of this paragraph (a)(4).” 12 CFR 1005.9(a)(4)
On the other hand, Regulation E requires the full account number to appear on a periodic statement:
- “Periodic statements. 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 an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred. The statement shall set forth the following information, as applicable:
(1) Transaction information. For each electronic fund transfer occurring during the cycle:
(i) The amount of the transfer;
(ii) The date the transfer was credited or debited to the consumer’s account;
(iii) The type of transfer and type of account to or from which funds were transferred;
(iv) For a transfer initiated by the consumer at an electronic terminal (except for a deposit of cash or a check, draft, or similar paper instrument), the terminal location described in paragraph (a)(5) of this section; and
(v) The name of any third party to or from whom funds were transferred.
(2) Account number. The number of the account.” (12 CFR 1005.9(b)(2))
To my knowledge there aren’t any other requirements requiring the full number or that restrict shortening the account number on statements or receipts. It’s a business decision outside of the above requirements.
Now that summer is almost over and thoughts turn to the fall/winter holiday season with store shelves packed with turkeys and tinsel, a common question is whether a credit union can be closed for consecutive days? Let’s say a credit union wants to give its hard-working employees additional time off to spend with family and friends, is there are requirement stating that credit unions can’t be closed for four days or more to make for a really long weekend? Well, folks, there isn’t a federal requirement for credit unions, but institutions will want to ensure that required processing and timing requirements are met for electronic payments, checks, and wires.