Yes, Reg. E will apply. If in the debit mode it was used as a branded Visa or MasterCard debit, those more stringent rules will supersede Reg. E. You can contract terms that are more favorable to the consumer than Reg. E, but not less favorable. (This assumes it is a consumer card.)
You'll find some helpful tools in the Banker Tool section of BOL to assist you with claims.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell