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Latest Operations - Reg. E Topics

Friendly Fraud Claims

05/01/2022

If a consumer knows the person that has taken or used their debit card, they are wanting to file a cardholder dispute on transactions that the friend/family member did, should we suggest that they may want to recover the money first, before we get involved and possibly contact the police or do we do the fraud dispute?

Is a Preauthorization a Reg E Claim

04/24/2022

If someone files a claim and you find that it was a preauthorization that fell off, do you still have to send a final letter, since no claim was started?

Customer Reminders - Device Security

04/17/2022

Can we use our phone as an access device for Reg E? Is there a way that we can ask the consumer if they have a passcode to access their phone?

Checks or debits presented after death

03/27/2022

When a decedent's checking account is debited after the death date, possibly with an unauthorized charge, can the estate present a valid claim to the bank with a copy of the death certificate as proof of authority? This is a sole account, not a joint account. The estate has debtors owed and a minor heir if that matters.

Charge Annual Fee on OD Line of Credit & Personal?

03/07/2022

Are we able to charge an annual fee on an overdraft line of credit and a personal line of credit? (We are doing Business in Massachusetts). We are looking for an open end product @ a fixed rate maximum APR of 18%.

What does not sending a written Reg E claim change?

12/19/2021

Clarification... if you require customer to return the signed claim form within the 10 business days for provisional credit and you don’t receive it, then you don’t have to resolve the claim within the 45 or 90 days?

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Customer okays purchase but doesn't get the goods

03/16/2025

A customer authorized a transaction with Apple Cash but says they didn't receive anything. Since this transaction was authorized by the customer, is this covered under Reg E's error claims rules?. The customer was attempting to purchase something on Facebook marketplace but never got the item.

Debit card logistics for banks without deposit account

03/09/2025

I have two questions relating to debit cards: 1. Does a bank have to have an ABA routing number for debit cards to function? 2. Are banks with no public depositor service able to use internal accounts as private checking accounts with debit cards to pay bank taxes and order supplies?

Sole proprietor changing to LLC

03/09/2025

We have a sole proprietorship DBA account under a Social Security number. The customer now has an LLC with an EIN. Do I need to change the account number or just update the signature card to reflect the LLC as the Primary and remove the DBA on the account?

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