07/17/2022
If a customer completes a transaction at our ATM and money is not dispensed, is this considered a Reg E issue?
Similiarly, if a customer completes the transaction and our ATM dispensed the funds but the customer forgot to take the cash, is this a Reg E issue?
06/26/2022
After a final resolution of a Reg E claim, how long do we have to notify the customer of the final outcome?
05/29/2022
Can you tell me the best practice or industry standard on how often an ATM should be reviewed for applicable electronic fee notice, audio output, Braille, skimmers, receipt reviews for date and time accuracy, etc.?
02/20/2022
Regarding 12 C.F.R. §1005.11 - Am I correct in understanding that consumer liability MAY be applied in the tiers but is not automatically applied to all of those claims in which it may apply?
For example, lets say we have a $74.00 transaction in question and the claim is that it is unauthorized. We determine that it is a fraudulent transaction. If we hold the consumer liable for $50 (granted they told us about it within 2 days of discovery) that means that we could not file a dispute (according to our vendor's procedure) because we would have to file for the full $74 and upon winning that dispute we would then profit from the dispute process as we are only "out" $24 at this point but would have an excess of $50 and no account to apply it to except Other Liabilities and we cannot offset our debit card losses with it. Let's say that we just hold the consumer liable for $50 and write off the $24 as a loss, which would make no sense to me either seeing as how our chargeback process is only $12 a claim.
Also, we have Visa debit cards so in saying that, if the transaction was not run through the Visa network, but say run through STAR, would our consumers not have the Visa Zero Liability protection since the card used has a Visa brand?
02/13/2022
Our bank offers early access to direct deposit funds, up to two days early depending on the timing of the submission from the payer. The bank wants to add an Opt-Out option for customers who prefer not to receive direct deposits early. Could you please confirm there is not a operational or regulation reason why the bank cannot accept an Opt-Out request either verbally or in an email. We want to make the Opt-Out option easy for the customer without requiring a signed form. The bank plans to document the customers name and date of request in an account note.
01/23/2022
I have a business customer with a business Mastercard debit card. They are disputing 100 plus fraudulent charges on their debit card with an online gambling website. When they came into the bank, they told the teller that they don't check their statements and only noticed the charges because one of their other debit cards was declined due to insufficient funds. I know this doesn't fall under Reg E, but what is the bank's liability in all of this? Does the Mastercard zero liability come into play?
01/23/2022
What is the requirement on sending monthly bank statements to commercial customers? Isn't there something in Reg E that requires customers to receive statements monthly because if there are electronic transactions that are fraudulent, they only have so much time to dispute them? So many of our transactions are electronic these days but we have a customer who wants to see their activity only quarterly. I feel that is too long to wait. I'm looking for proof that this is a banking requirement to send customers statements.
12/19/2021
If a client says the merchant was to issue a credit (refund) from a merchant but we didn't receive it, is that a Reg E error? If the client doesn't provide a receipt, how do you investigate?
12/19/2021
Customer cancelled membership (product) over the phone and the merchant has been charging the account. The customer has no cancellation evidence, but still receiving the product and the customer has not returned the item. Do we treat the claim as merchant dispute or unauthorized?
12/12/2021
If a transaction is pending and a consumer notifies us of this pending transaction and let us know it is unauthorized is that when the investigation timeclock starts? or when the transaction actually posts to the account