07/30/2012
Is there something in writing from the Federal Reserve and/or the CFPB that supports the comment in this<a href="http://www.bankersonline.com/operations/guru2012/gurus_op011612a.html "> Q and A</a> on Reg E periodic statement requirements? The Iowa Bankers Association, our compliance liaison from the Federal Reserve, and all other sources I can find seem to disagree with this point of view. They say the IF an account CAN be accessed by an EFT, regardless of whether it actually is, that at a minimum quarterly statements have to be provided (and also for each month when an EFT occurs).
07/09/2012
Scenario: John Doe is incarcerated in September. While in jail, John Doe's girlfriend takes his MasterCard debit card and makes multiple unauthorized ATM transactions at the beginning of October. John Doe stays in jail until the end of January of the next year. When released he looks at his online bank statement and realizes his card has been used for ATM charges back in October. Is the bank held liable to return funds to the customer if the charges are almost 90 days old?
07/02/2012
We are changing our debit cards from Visa to MasterCard. Do we need to send a new EFT disclosure?
06/25/2012
If we have closed a customer's savings account due to excessive transfers/withdrawals per Reg D, can we re-open the account later on, and if we can, is there a time period it must remain closed before it can be re-opened?
06/18/2012
Are board of directors and executive officers exempt from having Overdraft safeguard? What if they are listed in a non-owner relationship in a deposit account?
06/18/2012
I see that Dodd-Frank Act Section 1073 has an effective date of January 2012. Have we seen any final rules to comply with yet?
04/09/2012
We have a customer who has been in Afghanistan for the past 5 years due to their being in the military. The customer has come back to the United States and has discovered unauthorized withdrawals which took place 5 years ago - about a month after they were deployed. Are we in compliance if we deny the claim, or we obligated to pay due to fact our customer was not receiving statements to Afghanistan. The account was charged off in 2007 and customer discovered this on her credit report.
03/26/2012
Are Internet withdrawals of money market funds which transfer funds to another account of a customer at our bank limited by Reg D?
02/27/2012
Is ACH governed like a wire transfer? What electronic transfers methods are NOT regulated?
01/23/2012
I feel that my bank's operations unit has misinterpreted the Reg D provision limiting the number of transfers. They read the cycle to include quarterly statements on savings accounts and limit the six transfers per quarter not monthly. The depositor is permitted or authorized to make up to six transfers or withdrawals per month or statement cycle of at least four weeks.