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Latest Compliance - Debit Cards Topics

Reg CC and Debit Card Deposits

04/21/2024

Under Reg CC, how are deposits made by debit card treated? (These might be a deposit at an ATM or a merchant refund on a debit card burchase, as examples.) Can we hold these for three days even for existing customers?

When DOESN’T Zero Liability apply?

10/15/2023

Since Visa’s Zero Liability covers ATM withdrawals and PIN transactions. It is even worth investigating Reg E claims since we are always on the hook?

Business debit card disputes

10/15/2023

Since Reg E does not apply to businesses, do we have to investigate a fraudulent business debit card transaction?

Fraud using Visa Secure 3-D

10/01/2023

Our processor says we don’t have chargeback rights since a purchase was made using Visa Secure 3-D. Can we deny the claim since the cardholder’s password was used?

Reg E and mobile payments

09/24/2023

Our customer received a call telling them their CashApp account was compromised, and they needed to verify the password. After they did this there were several authorized CashApp transactions. Can we tell the customer they have to resolve the issue with CashApp?

Error Claims and Provisional Credit

09/17/2023

A customer purchased KETO Bites and states the cost was $39.99. She immediately received an invoice along with charges to her account for the amounts of $59.99 and $239.99, not for the $39.99. Does provisional credit need to be given for those amounts and is the dispute considered fraud?

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Is permission required to use ChexSystems?

02/23/2025

We use ChexSystems for deposit accounts. We have a legitimate business need/permissible purpose to run Chex on those looking to open a consumer account. Do we need to be obtaining written permission from the consumer prior to running Chex?

GMI Collection for a Bank, by a Broker

02/16/2025

If a broker submits an application for a multifamily loan to a bank on behalf of a mutual customer, is the broker required to collect HMDA GMI data? Say the customer "does not wish to provide" the data, would the broker need to collect the information on the basis of visual observation or surname and communicate that to the bank?

Who Gets the Adverse Action Notice?

02/16/2025

Our denial of a business deposit account application was based on the qualifile score of the individual applying for the business. Who gets the Adverse Action Notice?

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