Proposed changes in electronic funds transfer rules would unduly limit bankers' discretion, according to comment letters filed at the Federal Reserve.

Everything from how customers are informed about fees to what must be included on cash withdrawal receipts would be dictated by the new EFT rules, bankers charged.

Regulation E, implemented in 1978, defines what fee and other information on electronic fund transfers financial institutions must disclose to customers.

The regulation also limits consumer liability, establishes uniform transfer rules, and states what banks must print on receipts.

The Fed issued its latest plan to revise Reg E in February and took comments on it until late May. The central bank could take final action on the proposal anytime.

The most critical comments came from operators of automated teller machine networks, who argued that the Fed rules were technologically impossible to implement, dangerous for consumers, and unfair for banks.

James H. Hayes, senior vice president of Cash Station Inc., claimed the proposal would require every ATM to disclose the fees that every member bank charges.

He said that would be impossible.

"Such a requirement would be the equivalent of requiring every merchant that accepts a check... to disclose to the consumer any fee that the consumer's financial institution may charge for the payment by check," Mr. Hayes wrote.

Noel H. Nation of Miami's Baker & McKenzie law firm, who represents the Honor electronic banking network, said the Fed needs to change the requirement that automated tellers print the customer's card number on receipts. The numbers don't help consumers, only criminals who use them to break into the system, Mr. Nation wrote. The proposal states that the Fed's intent was to provide a unique receipt for each customer.

Mr. Nation asked the central bank to allow ATM operators to, as the Secret Service has suggested, print a truncated version of card numbers.

State Employees Federal Credit Union vice president Dennis J. Gastonguay objected to a rule absolving consumers of responsibility for most ATM fraud.

"To allow consumers to escape liability in cases of blatant and gross negligence is not only unfair but downright costly," Mr. Gastonguay wrote.

"Consumers who give out their PIN numbers or write them on the card or envelope they keep their card in should be made liable for losses suffered as a result."

Banks also questioned a requirement that they notify customers when electronic transfers do not occur.

"Many times we are not even aware that a customer is to be receiving a certain deposit," said Anne Williams Talbott, the assistant vice president of Halstead Bank in Kansas. "This is especially true for Social Security benefits, for which we receive no prenotification."

Nearly all of the more than 50 letters supported changing the definition of "business day" to any day other than a Saturday, Sunday, or legal holiday.

This matches the definition found in other regulations. The definition, used to determine how quickly the institution must respond to electronic transfer errors, currently applies to all days the bank is open.

"Consistency among regulations governing deposit accounts should facilitate compliance," wrote John Shivers, president of the Independent Bankers Association of America.

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