Given the limited experience with SV products to date, it is difficult to assess the extent to which the benefits to consumers from the application of any particular Reg. E provision might outweigh the corresponding costs of compliance. Even partial application of Reg. E's requirements to SV products could impede development of the new payment products, and thereby adversely influence the payment options available to market participants in the future. The existing legal framework provides considerable incentives for providers of SV products terms to avoid unconscionable or unfair terms and to make adequate disclosures about SV products.
E is based.
For example, to the extent that electronic signatures or encryption are used to authenticate transactions, the identity of certificating authorities and the degree of protection afforded by a certificate may be an important fact for consumers to know. Similarly, the increasing implementation of SV products as multiple-use cards may affect the disclosure, risk and notice features of Reg. In this regard, we are likely to see an evaluation of thought on the proper role of Reg. E or its successor in a technologically enhanced financial environment. All rights reserved.