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Latest Compliance - Operations Topics

Mobile deposit chargeback and indemnity

10/08/2023

My back accepted a mobile-deposited check that was returned by the paying bank as “previously paid.” Our depositor has apparently left town – his account with us is closed. The paying bank told us the check had been mobile deposited at a local credit union two days before it was deposited with us. Do we have any claim against that credit union to recover our loss?

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?

Handling Reg E claims on older transactions

08/20/2023

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

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Unauthorized Authorized Debits

09/29/2024

If a customer authorizes someone to use their card and gives them the PIN for a specific transaction, and that someone uses the card for additional transactions that were not authorized by the customer, is their any negligence by the customer for giving the card and PIN for the first authorized transaction? What are the requirements according to Reg E ?

CD Renewal Rate Disclosures

09/15/2024

I have a question about a CD special. The bank's rate sheet lists a 12-month CD as well as a 12-month CD Special that has a considerably higher interest rate/APY than the regular base CD. The bank also allows negotiation and will pay a higher rate to keep business. For the "special" and any other negotiated rate, the rate is only in effect for the initial term and at maturity will renew at the 12-month non-special rate. I'm looking at 1030.5; Comment 5(a)(1)-1 and I am thinking that advance notice would be required since the terms are changing upon the occurrence of an event (renewal). There is nothing on the TIS disclosing that the initial term is a promotional period and that the CD will renew at the lower non-special rate in effect. Am I thinking about this correctly?

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