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#1522751 - 03/16/11 09:09 PM Reg E Claims & acct access third party websites
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 816
NY
Hi,

Can a bank deny a claim for unauthorized activity in their bank account if the customer has used third party services (not affiliated with the bank) such as www.pageonce.com or www.mint.com where the customer provides bank account login information (user name, password) to the third party? FYI - these sites (pageonce.com and mint.com) are services where a person can see all their financial data in one place. There are mobil apps for these services as well.

Thanks.
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Operations Compliance
#1522814 - 03/17/11 01:10 AM Re: Reg E Claims & acct access third party websites happyauditor
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,442
Galveston, TX
See Sec. 205.14 Electronic fund transfer service provider not holding consumer's account.
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#1523000 - 03/17/11 02:17 PM Re: Reg E Claims & acct access third party websites rlcarey
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 816
NY
Thnaks rlcarey but I need to clarify. The third parties I mentioned do not allow any transactional capability, merely "see all your accounts in one place." You can also set up alerts I believe for certain crieria (maybe balance falls below $XX), but in a nutshell, no transactional ability.
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#1523107 - 03/17/11 03:16 PM Re: Reg E Claims & acct access third party websites happyauditor
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Whether or not you can deny a claim depends on the nature of the claim. You haven't stated the type of claim you're interest in. Allowing those aggregators to access a bank login page to pull down balance info doesn't create a transaction that would be challenged by your customer, and you've suggested they don't do transactions through those sites.

So under what conditions do you anticipate you'll receive a claim?
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BankersOnline.com
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#1523513 - 03/17/11 08:13 PM Re: Reg E Claims & acct access third party websites John Burnett
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 816
NY
Hi John,

Suppose this scenario: Customer discovers unauthorized electronic debits (for example bill pays) posted to his account and notifes the bank. The bank knows (maybe the customer tells the bank) the customer has "shared" his logon information with pageonce.com or mint.com. Can the bank deny the claim stating the customer has shared his logon information? For example, the bank suspects a pageonce.com or mint.com employee has stolen the customer's logon credentials (or someone hacked those sites)and signed onto the customer's bank account (your bank website) and set up electronic bill payments.

I am guessing you cannot deny the claim based on this type of scenario similar to not being allowed to deny a claim when a customer writes his PIN on his ATM card.

Thanks.
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* My opinion is not necessarily that of my employer.

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#1523523 - 03/17/11 08:19 PM Re: Reg E Claims & acct access third party websites happyauditor
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,442
Galveston, TX
You cannot deny a claim based on that premise.
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#1523532 - 03/17/11 08:30 PM Re: Reg E Claims & acct access third party websites rlcarey
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 816
NY
Thanks - that is what I thought! smile
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#1523555 - 03/17/11 08:55 PM Re: Reg E Claims & acct access third party websites happyauditor
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Randy was quicker on the draw than I (after all, he's from Texas, and I'm not). wink smile
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1523565 - 03/17/11 09:06 PM Re: Reg E Claims & acct access third party websites John Burnett
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
grin laugh
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