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 ?
08/25/2024
We have a customer that lost their debit card but didn't notify us until day five. Under Visa's zero liability policy, would this be considered "gross negligence"? The charges do not all add up to $500.00, so are we required to give the customer any credit at all?
08/25/2024
Scenario: A bank employee inadvertently makes an error while processing a payment authorized by phone by the customer, for example, customer authorized his/her personal loan monthly payment of $100 but the employee processes a debit for $101, or $96.
Could this be considered an unauthorized electronic fund based on the amount error? Can this be considered a violation of other consumer protection law/reg? UDAAP?
08/18/2024
Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window?
Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.
08/11/2024
Can a merchant force a debit card transaction by claiming that the transaction is a recurring transaction event though it's not? For example, the customer opted out of overdraft service for ATM and one-time POS debit card transactions, but a merchant forced the transaction by claiming it's recurring.
05/12/2024
Can a bank use the customer’s history of access to their online banking, to determine when the customer was aware of a loss such as an unauthorized electronic funds transfer?
04/28/2024
If a customer did not receive their check in a timely manner in the mail after cashing in a Certificate of Deposit, can they file a Reg. E claim? The account was originally opened online.
04/07/2024
According to Reg E, if I need to reverse provisional credit from a customer and they do not have the funds in the account in the amount of the reversal, can I proceed even though it will leave the account in the negative? The customer has been notified verbally of the reversal and I will send the reversal letter via mail, but they have made no attempt to deposit the money to cover this. Can I proceed, regardless of if the funds are available and still be in compliance?
01/21/2024
What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?
01/07/2024
We currently have outside counsel providing what I believe is inaccurate guidance. However, I'm struggling to find resources I can use to refute their regulatory interpretations. Specifically, this applies to a consumer's right to stop payment under 1005.10(c). Can you please advise how these requirements apply to:
1. Preauthorized transfers for loan payments (we are the lender/servicer) drawn on both external (we obtain debit authorization) and internal deposit accounts; and
2. Preauthorized bill payments both issued against the bank's/vendor's account and debited directly from the consumer's account. We hold the consumer's deposit account and offer the bill pay service.