08/06/2023
Are financial institutions required to have a cardholder sign a dispute letter when filing a Reg E dispute on a debit card, or can a dispute be filed verbally and with no signature?
04/16/2023
We have a very small subsidiary bank whose contract with its core systemes provider is not being renewed. The bank obviously needs a temporary core system until they close a new contract with another provider.
One proposed solution is to onboard the small bank's 100 or so customers onto our core. We would manually process the small bank's transaction files from imported data, which our IT teams are handling. Bottom line, the small bank will retain its ABA#, but their debit cards will have to be reissued by us, the larger bank, and during the transition the cards will bear our name.
My concern lies in disclosures and compliance. What disclosures do we as the larger, "host" bank need to provide to the smaller bank's customers while their accounts are serviced by us, on our system? The smaller bank is a digital-only bank.
03/19/2023
I have heard that business accounts do not fall under Reg E. How does this apply to internet banking and what about a business account that is a sole proprietorship?
03/19/2023
A customer disputed a transaction saying that they were scammed. The bank filed the dispute through their dispute program with a well known vendor I'll refer to as V. This was on October 20.
V submitted the claim to the merchant on December 12, and they responded with evidence that the customer initiated the transaction. It went into pre-arbitration and the bank did not hear anything further. At 90 days the bank closed the case with the customer being responsible because the merchant said the evidence proved it was the customer who did it.
On January 30, the bank received credit from the merchant stating that there was an error and they are now returning the funds.
The bank contacted V since it had been past the 90 days and were told that the merchant has 30 days once they receive the dispute, then when the bank gets the results, they have 30 days for pre-arbitration, then the merchant has 10 days to respond to that. This doesn’t to fit with Reg E time requirements.
There is some confusion as to how the bank should handle this situation. They would like to return the money to the customer, but are unsure of how to proceed. What should happen in this case and was it mishandled based on Reg E and merchant rules?
03/12/2023
Must we go through the formalities of an investigation and document what we’ve done such as paying provisional credit on claims that were made timely?
03/12/2023
I attended a great training webinar presented by BOL Guru Brian Crow on Mastercard vs Reg E rules. During the presentation he mentioned three Mastercard chargeback forms the bank could use in lieu of a signed cardholder document. Our operations department located two of the three. My question is, to inquire about the document form number for the "Expedited Fraud Dispute Form".
03/05/2023
Why can't we hold customers liable for carrying their PIN with their card?
02/19/2023
A customer had a charge out of his account six months ago. That’s old and means he has unlimited liability so we don’t have to investigate it. Is that right?
02/12/2023
Why is a permissible purpose needed to get someone’s credit report?
02/12/2023
What action steps are needed when we find a severe or frequent violation?