Most Popular Compliance Content
Licensing Privately Owned ATMs & ATM Operators
06/09/2019
FFIEC Guidance on Privately Owned ATMs is ambiguous regarding registration and licensing requirements of Privately Owned ATMs and ATM Operators. Where can we locate specific guidance regarding licensing requirements by State/Parish/County for Privately Owned ATM Operators? We know what licenses are required by an entity to conduct business in general, however have not able to locate specific requirements for States other than those in the North East for registering and licensing Privately Owned ATMs and ATM Operators.
Decline Dispute if No Evidence of Invalid Error?
06/09/2019
Our customer says "I canceled my account with the merchant" but does not provide any documents showing the account was canceled or says "my bill was suppose to be $23.00 but I was charged $37.00 and does not provide a receipt. Can the bank, since there is no evidence the error was invalid, decline the dispute?
Legality of CBD under New Farm Bill
06/02/2019
I was told the 2018 Farm Bill legalized CBD. Is that true?
1026.53 Payment Allocation- Definition of Balance
06/02/2019
1026.53 - Payment Allocation reads pretty clear - payments in excess of minimum payment must be made to the balance with the highest APR and then descending until the payment is exhausted. But "balance" is not clearly defined. One could argue there could be two different balances. Cycle to date balances (in current cycle) or cycled balances (prior cycle) For example; suppose a card holders billing cycle is the 1st – 31st with a payment due date of the 21st. The account has the following balances that rolled over from prior cycles; $10,000 BT Promo at 0% $225 Purchase at 11.99% On the 21st the card holder makes their minimum payment of $25 which is applied to interest, fees and balances on the account in accordance with Regulation Z. On 23rd the card holder makes a $500 purchase at 11.99% and a $2000 cash advance at 12.99%. On the 28th the card holder makes an additional payment to the account of $3000. Should the additional (excess) $3000 payment be in the following order; $2000 to the cash advance balance at 12.99%. $700 the purchase balance at 11.99% $300 to the BT Promo at 0% or Do not apply any of the excess payment to the transactions that occurred in the same cycle. Alternatively, the payment is applied to the balance in the prior cycle: $200 to the purchase balance at 11.99% $2800 to the BT Promo balance at 0% and nothing to the cash advance balance What is correct?
Reg Z- VISA Open Loop Card "Replacement"
06/02/2019
The bank has used "replacement" to replace a private label card with a VISA open loop card. Some of the cardholders have not activated their cards, some probably because they threw away the envelope without opening their mail. The bank is considering placing a block on the cards, pending activation from the customer so that the customer can still activate rather than reapply. The other option is to send a letter to activate the account within a stated time, otherwise the account will be closed. The consumer would need to apply again for a card. IMO, the second choice is a better customer experience in the absence of some foundational regulation to assert one position or the other.