Regulation E and Digital Banking Fraud: What Financial Institutions Need to Know
Fake banking sites aren’t just a customer problem. CFPB guidance makes clear that when a fraudster obtains account access information through deception and uses it to initiate a covered EFT, the transfer may qualify as an unauthorized EFT under Regulation E. That means cloned login pages can create investigation obligations, provisional credit requirements, and reimbursement exposure for banks, even when the customer typed the password themselves.