Most Popular Compliance Content
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?
Reportable SAR Amounts
03/19/2023
When filing SARs, for the total amount of reported activity would you include both incoming and outgoing transactions when it's the same funds? Example: Customer received an unusual wire for $50,000 and withdrew the funds in a structured manner. Would the total amount reported be $50,000 or $100,000?
P2P Claim, No Agreement with Vendor
03/19/2023
I have a Reg E Section 1005.14(a) question. If a consumer is disputing a charge that originated as an ACH from a P2P or other fintech and we do not have an agreement with the P2P or other fintech, can we as a financial institution direct the consumer to file their dispute with the P2P? Aren't they subject to Reg E Section 1005.14(a)?
How can I gain a full picture of customer activity?
03/19/2023
How can I gain a full picture of customer activity?
Are bank statements required?
03/12/2023
I am looking for clarification on deposit account statements that must be provided for checking or savings account activity, both consumer and business. Reg DD does not require a periodic statement for consumer, but Reg E does, monthly if there is Reg E activity and quarterly if not. What about business accounts since neither Reg pertains to those? If not a requirement, is it a best practice?