06/16/2008
Can you provide an interpretation of Reg E Section 205.10? It states, "the financial institution must honor an oral stop-payment order made at least three business days before a scheduled debit. If the debit item is resubmitted, the institution must continue to honor the stop-payment order". It further states under revocation of authorization "once the financial institution has been notified that the consumer's authorization is no longer valid, it must block all future payments for the particular debit transmitted by the designated payee-originator." Is the bank covered if their policy is to place a stop payment for a specific time frame? Is the bank required to block all similar transactions (same originator not necessarily the same amount) indefinitely?
06/09/2008
We have just opened a new branch that has an ATM with check imaging capabilities for deposits. They are talking about the branch balancing (taking out the deposits and posting them to our GL) once a week. All our other ATMs get balanced every day. Is there any regulation that requires ATMs that accept deposits be balanced daily? I am concerned about this weekly balancing, if a customer enters the wrong amount on a deposit or if there is a presenter error, and the customer does not notify the branch. Aren't there time limits on correcting these things?
05/05/2008
What regulation covers internet banking bill pay?
01/07/2008
In your article on Reg D, <a href="http://www.bankersonline.com/compliance/gurus_cmp080502o.html">Transfer of Funds: Do sweeps count against the transaction limit?</a>, you pointed out unlimited transactions between accounts at the bank, done at an ATM, in person, made by mail and Direct Customer Contact. Now where does the merchant capture device fit in this picture, since you have basically taken the bank to them with direct access to move money between their accounts. It seems the customer is standing in front of a piece of equipment very similar to an ATM. Should these transactions count?
10/15/2007
How are banks that are exchanging images providing the actual checks to their customers who have requested to receive their original items back?
09/03/2007
How are banks that are exchanging images providing the actual checks to their customers who have requested to receive their original items back?
05/21/2007
Our bank recently converted to item-capture imaging. Instead of sending the original copy of a check back with the statement, we have included an image of that check (five to a page). We first told our customers that this image of the check was a legal copy of the check and it contained both front and back images. Now, we have chosen to only image the front of the check to save paper. Is the image of only the front of a check still a legal copy of the check? Should we include the front and back image of a check?
04/30/2007
Should a bank allow ACH transactions on home equity lines of credit that are generally accessed by a check? Consider that some checks are converted to an ACH transaction. Under what Regs would these types of transactions be governed and what is the risk to the bank and to the consumer?
04/30/2007
What regulations should be considered as we write our Remote Capture policy (Check 21, Reg E, Reg CC, etc.)?
04/02/2007
If we image all checks received for deposit at our main office (using remote capture), how long must we retain the actual physical check? We use [Electronic Clearing Network Name Withheld] to send checks electronically.