05/10/2010
Many of our commercial clients originate ACH files and some transactions get returned for insufficient funds, etc. When an ACH transaction is returned to us, we charge it back to the client’s account, much like we do for returned checks. We have a couple of clients who have asked for an individual ID to appear on our ACH Return Notices, along with appearing on the transaction itself (though DDA and/or Online Banking history), and appearing on the DDA statement. We have a procedure in place that stops this information from printing on the original ACH transaction for consumer clients. Many of them complained, since this field may contain social security numbers. There is no regulation on what has to appear in this field. It may contain a SS number, but may also contain other information. I have seen a mix of things in this field ranging from a blank field, to a person’s name, to a string of numbers and letters that do not mean anything to me. Basically, we hide this field from consumers due to their complaints. The situation I am asking about is slightly different, but I would still like to confirm with you that there are no regulatory or privacy issues. For the custom we are getting ready to ask for, it will show the information that is in this field, it will show it on the actual return notice, it will print it on the statement, and will also appear through DDA and OLB history. The difference here though is that the client who sees this information on his return notice and on hus statement is the same client who populated that field, so I do not think it will be an issue, since it is information that the client provided to us originally, and that he already has access to it, but I wanted to double check before we get too far down this road.
02/15/2010
We are a small community bank and do not have an overdraft protection program. Do we treat all our customers as opt-out come July 2010?
02/08/2010
In regards to the Reg E changes effective 7/1/2010, does the prohibition against charging fees on ATM or one time debit card transactions apply if you don't have any kind of courtesy overdraft program? For example, our bank does not authorize card transactions if there is no money in the account, however, at times checks or other transactions come in and pay out of the account before the card transaction posts, and since they have been authorized, we have to pay them. Will we be required to provide the opt-out notice?
01/04/2010
When the new Regulation E amendment becomes effective that prohibits opt-out programs for overdraft services for ATM and one-time debit card transactions, will we have to change our opt-out program for other types of overdrafts?
11/02/2009
We no longer accept deposits at our ATMs, so we no longer display "Funds Availability" on the screen. However, would we still need to display Funds Availability to our customers who transfer funds at the ATMs?
09/28/2009
Currently, our ATMs do not accept deposits. We have never had a customer make a deposit at another bank's ATM either. However, we do have accounts all over the country and it would be convenient for them to be able to make a deposit at an ATM rather than mailing it to us. We are thinking about starting to market this option to them, but are wondering what rules and regulations we need to be aware of first, or if there is anything else we would need to do to implement this?
07/13/2009
If an authorized signer on an account already has an ATM card, can we automatically issue them a debit card? Can an authorized signer come and order a debit card, or would the owner of the account have to come order it for the authorized signer?
05/25/2009
I know this is a basic question but can someone explain stop payments that are subject to Reg E?
11/03/2008
We had approved and closed a Reg E claim prematurely and the merchant later represented with a copy of a receipt that bears our cardholder's signature. Can we now reverse our decision and debit the client's DDA? If so, do we have to send a new resolution letter?
07/14/2008
We are thinking about offering E-deposits to customers. The customer would go into the home banking application, enter the amount of the deposit and the check information then physically mail us the paper check. The customer would receive immediate availability on deposits up to a specific limit. Once checks are received (within 5 days) we verify the check information and process the checks normally, but do not post the funds. If the checks are not received in time, we can extend the time requirements. What type of transaction is this considered and which regulation does it follow? Reg D, DD, E or Z? Do we have to provide special disclosures and if so, which ones?