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#1975446 - 11/10/14 02:31 PM Business Debit Cards Agreement/ Disclosures?
Anonymous
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Being that a Business Debit Card is not covered under Reg E are banks required to issue a "Business Debit Card Agreement" when issuing a new debit card? We currently do provide one to our customers but in what Regulation is this covered, if any, that a disclosure is necessary?

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#1975453 - 11/10/14 02:52 PM Re: Business Debit Cards Agreement/ Disclosures? Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
It is a matter of contract, of laying out the rules. How will the customer know the rules if you do not provide them?
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#1975459 - 11/10/14 03:14 PM Re: Business Debit Cards Agreement/ Disclosures? Anonymous
Anonymous
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I agree, it is certainly best practice, and probably a requirement of Mastercard, I was just trying to determine if this a requirement and the applicable law/ regualtion.

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#2063726 - 02/10/16 10:35 PM Re: Business Debit Cards Agreement/ Disclosures? Anonymous
tryin2comply Offline
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Joined: Jun 2013
Posts: 90
Along the same lines of this topic, are agreements required to be signed by the cardholder? I was recently asked by another CO if cards, with disclosure verbiage, could be sent to customers without their request for the card? For example, a debit card would be sent with the verbiage about "using this card shows your agreement to the rules contained in the attached disclosure". I am unsure if that's an option. I cannot locate any information regarding the signed agreement. I would argue that the signed agreement would be the only way to prove the business had agreed to the terms and conditions of the debit card. Additionally, if they wanted a debit card for an employee, I would think that there would have to be some sort of signed agreement stating they take responsibility for authorized signers behavior with the company card. Thoughts?

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#2063739 - 02/10/16 11:04 PM Re: Business Debit Cards Agreement/ Disclosures? Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
You need to be exploring the thoughts of your legal counsel on this issue.
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