Answer:
No 203.5(a)- Comment 3. Foreign applicability. Regulation E applies to all persons (including branches and other offices of foreign banks located in the United States) that offer EFT services to residents of any state, including resident aliens. It covers any account located in the United States through which EFTs are offered to a resident of a state. This is the case whether or not a particular transfer takes place in the United States and whether or not the financial institution is chartered in the United States or a foreign country. The regulation does not apply to a foreign branch of a U.S. bank unless the EFT services are offered in connection with an account in a state as defined in Section 205.2(l).
Additionally, if you are issuing cards to NRA's, you might want to check your card issuer's agreement. I know for VISA cards, you use to have to have an international card issuer's agreement with them and it was expensive.
First published on BankersOnline.com 9/01/08
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