05/20/2013
A large national retailer is now issuing in-store debit cards, that post transactions to our bank customers account as ACH debits. These are not credit cards - they are debit cards for use only at the designated retailer - swiped and signed just like any other card - only debiting the bank account. Our customer signed up for the card at checkout, provided her banking information, and received a discount for her purchase. One month down the road, she has $900 in debit card purchases that have posted to her account on a card that she says she never received. Can you please describe what would be considered the best practices for a bank in a dispute situation like this? And does the large retailer have a Reg E responsibility here, too? I am particularly thrown here because it is clear that she authorized the ACH debits - but the card purchases were fraudulent. With no control over the instrument or the agreement associated with it, we feel a little blindsided by this new type of dispute.
09/12/2011
Is there any compliance restriction that would prevent us from changing a customer’s due date on a HELOC if the customer generates the request? I know there were some restrictions about changes to due dates that were part of UDAP requirements for credit cards, but I do not believe HELOCs were impacted and I do not believe request for changes that came from the customer were problematic.
05/30/2011
We have an upcoming FDIC Compliance Exam. In the pre-exam questioning, I was asked if we provide a "Conforming Loan Payment Notice". I thought this was just for the credit card payments but was told that this also involves "payments on residences". I have searched for some type of guidance and have only found information that pertains to credit cards and helocs. In "googling" the topic, I have found several banks that have the disclosure on their website. This is telling me that I have certainly missed something. Could you give me some guidance or somewhere to look further?
04/11/2011
Does the reasonable cutoff time of 5pm for Reg Z still apply when you only have HELOCS and not credit cards?
12/06/2010
Are there any regulatory issues or restrictions for a bank becoming a credit card merchant and accepting loan payments from borrowers via debit or credit card?
10/18/2010
The bank wants to give a gift under $25 for all customers who fill out applications for credit cards or loans. This promotion will be held at branches in certain areas, but not statewide. Flyers will be available at all the personal bankers' desks. What would be the compliance requirement?
04/13/2009
We offer business credit cards through a third party vendor. The bank currently approves the applications and handles disputes. We are now going with a company that approves the applications and handles all disputes. This company bought all the consumer cards, but did not purchase the business ones. We want to send a letter to the business customers and let them know we are no longer offering business credit cards and within 60 days the cards will no longer be active. Are we in violation of Reg E or Z by doing this?
03/16/2009
I work for a third-party service provider for financial institutions in the compliance area for credit cards. I am trying to get my hands around a procedure due to non-compliance and there is no definition of POS that I can find. The problem is that I am fighting with the manager regarding the error resolution 45-day requirement vs the 90-day requirement. She is telling me that everything we do is POS and I need to verify that. My thoughts about a POS were that it was always a pin-based transaction and if you use your debit card as a credit card through Visa or Mastercard it falls into the Reg Z realm. Can you help me with this?
03/19/2007
Does a Disclaimer Of Oral Agreements for loans over $50,000.00 only apply to commercial loans or to consumer loans as well?
05/22/2006
Are there any specific size/readability requirements relative to disclosures for Member FDIC,Equal Housing Lender Logos, and, if applicable, disclosures relative to TISA or TILA on billboards? I'm having difficulty understanding what is meant by "clear and conspicuous standards" and am interested in knowing if there are standards for the readability of these disclosures? Is there an industry practice relative to inches of fonts (regardless of the size of the billboard)?