03/28/2011
We are thinking about adding loan notices (i.e. pmt notices/past due notices/ maturity notices/ rate adjustments/ etc.) to our list of items that a customer can sign up to get electronically. We already do it for deposit products (stmts and such). I realize I need to consult the applicable lending regs, most of which I believe defer to the esign act and allow for electronic delivery, but I'm just wondering if I'm missing something. I guess I'm a little nervous about sending someone's past due notice electronically even if they have to elect to receive it and confirm that they can (call me cautious). Is there anything else I need to watch out for? I am happy to do my own research but if you know of any prohibitions or can point me to something I'm missing, I would appreciate it.
01/24/2011
There was a question in the Infovault about charging non-customers a fee for performing a cash advance when using a VISA credit card, which appears to be prohibited per VISA participation rules. However, would there be any issue with charging an ATM surcharge to all non-customers making cash advances at an ATM using a credit card (so long as an onscreen notice for the amount of the surcharge allowing the customer to cancel, was present)?
01/03/2011
We have accounts that have debit cards. Can we still make a requirement that restricts paper statements from being delivered? Can we make it a requirement to have e-statement or none?
11/29/2010
It seems the proposals as to what fee disclosures should be on an ATM have been going on forever. At one time they stated we had to disclose this by sign on the machine and on the screen. At some point they said the fee amount needed to be disclosed in the notice. The final regulation reads like the disclosure could be on the machine or on the screen. There is no mention of disclosing the fee amount for foreign transactions. Can I assume we only need to post the notice on either the screen or a sign on the machine now, and can I assume we do not have to post the fee amount?
11/29/2010
We are deciding whether or not to provide e-statements on our internet site. What are the required disclosures needed to provide this service? I understand that the customer can choose whether or not to receive his/her statement electronically.
11/15/2010
Does Reg E allow us to deliver the required notification letters via email?
10/18/2010
I work with commercial deposit and treasury management products. Would it be possible to provide new account documents (TandC), TM contracts, and signature card to the customer on a flash drive versus a paper copy?
09/20/2010
We are in the process of starting e-statements for our customers. They will have to sign into our secure internet banking site to view their statements. However, the statements will be coming from another imaging company that does our imaging processing. These two companies are forming a single sign in for the images. I keep hearing about "demonstrable consent"; would we still have to prove this with our customers signing into a site that they have been or does this rule apply because it is the customers' actual statements being viewed?
08/09/2010
At the end of March, one of our customers filed a dispute on two transactions where the merchant processed them as PIN-less debits. The customer maintains that he did not authorize the transaction, and that the merchant refuses to provide a refund. The customer was well within the sixty day guideline for filing a claim, but now is threatening to sue us because we have not processed the claim within the forty-five day timeline required by Reg E. We did not provide the client with provisional credit after day ten, nor have we provided the client with any written communication regarding the claim. Are we liable to the client for failure to follow Reg E, and what can we do to get out of a lawsuit?
08/02/2010
We have set up a computer for customer use in some of our branches. Besides doing on-line banking, customers can apply for mortgage or equity loans. Must we provide a printer with this computer or is that optional?