Most Popular Compliance Content
How can I gain a full picture of customer activity?
03/19/2023
How can I gain a full picture of customer activity?
Check Return Timeline
03/19/2023
I wanted to reach out in regards to time frames that depositing banks have to respond to a check return. As with most other banks, I’m sure, we have seen an increase over the last 2 years of check fraud alternating between both altered checks and endorsement fraud. We typically try and return the item and collect for our customers the lossed funds, but most of the time our returns are denied as they are a late return. The denials that we receive though range from 2 weeks – 3 months so I wanted to reach out to see if there is a time frame that a depositing bank has to deny a returned check so we know on our end as far as giving our customers final credit for the check return?
Conflict Between Reg E and Merchant Rules
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?
Seeking Expedited Fraud Dispute Form
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".
When to do CDD on loan app
03/12/2023
For loans that take months from application to closing, at what point would you recommend collecting updated Customer Due Diligence? My initial thought is that as long as the loan had not closed, we can rely on the information from the previous 90 days, but would want to verify/update after that period, and I am having difficulty finding guidance on specific timing.