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Debit Card Disclosures For Commercial Customers

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Question: 
What disclosures, if any, should we provide to a commercial customer who requests a debit card?
Answer: 

There are not really any required disclosures, but there are some contractual issues you'll want spelled out. First, you'll want to make certain the customer agrees that none of the transactions will be subject to Regulation E's consumer protections. Second, you should make sure, if any cards will be issued to "authorized users," the customer understands its responsibility to notify the bank if the customer wishes to terminate use of any of the cards. Third, there should be an understanding as to daily limits. Fourth, the customer takes all responsibility for use, including any "unauthorized" transactions that an employee might make.

There may be other things you want to lock into this little addendum to your deposit contract.

First published on BankersOnline.com 05/5/03

First published on 05/05/2003

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