Most Popular Compliance Content
Discontinuing cash advance service
09/01/2024
Can a bank offering VISA cash advances stop offering cash advance services?
Does one mistake make a business an MSB?
09/01/2024
We have a commercial customer that cashes checks, but they are not registered as an MSB because they have a policy to not cash checks for one person over $1000 in one day. We found one instance of checks cashed over $1,000 for one person. Are we required to have the customer register as an MSB, or can we verify their check cashing policy and continue to monitor the account for any further instances?
Consumer Protection for mistake in loan payment transaction
08/25/2024
Scenario: A bank employee inadvertently makes an error while processing a payment authorized by phone by the customer, for example, customer authorized his/her personal loan monthly payment of $100 but the employee processes a debit for $101, or $96. Could this be considered an unauthorized electronic fund based on the amount error? Can this be considered a violation of other consumer protection law/reg? UDAAP?
Lost Debit Card
08/25/2024
We have a customer that lost their debit card but didn't notify us until day five. Under Visa's zero liability policy, would this be considered "gross negligence"? The charges do not all add up to $500.00, so are we required to give the customer any credit at all?
Records retention and canceled remittance transfer
08/18/2024
Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.