07/11/2011
In most cases, when an EFT error (ACH) is reported to us, the investigation is initiated immediately and completed within 10 days. Our bank requires written confirmation for all EFT errors that are reported. We realize that without written confirmation, it does not delay the initiation or completion of the investigation. However, what are our requirements for crediting if the customer does not give us written confirmation within 10 days? Do we have to follow the provisional credit rules? Or do we just let the reported error “hang” until we get that written confirmation?
01/31/2011
I have a debit card dispute on 52 transactions (all from the same merchant) with dates ranging from 9/26/10 thru 11/21/10. This customer states that the merchant contacted her about the possibility of fraud on 11/19/10. On that same date, she contacted our bank and had her card cancelled. She did not file a dispute with us until 1/26/11 because she claims she has been working with this merchant to resolve the dispute. My question is, what date should be used in determining the 60 day statement guideline for provisional credit? Should we consider 11/19/10 as the notification date, or 1/26/11?
12/13/2010
Our financial institution wants to offer atm/debit cards to minors. I was hoping for some direction with the following: <ul><li>Do we need specific information about this in the EFT disclosure?<li>If we offer cards to minors between 14-18 is there a discrimnation issue?<Li>I am assuming we need to have a liability form signed by the parents any thoughts on what should be included?</ul>
11/15/2010
We got an EFT from our customer service department, where the customer did not give us a signed EFT by the time the timeframe was up. Are we able to decline for non-receipt of a signed EFT?
04/19/2010
How do you determine the difference between a "check card dispute" and "check card fraud?" If a customer claims he did not make the transaction, but the merchandise was shipped to his address, can we deny the claim? If a merchant verifies the security questions through Visa, and the transaction is approved, is the bank obligated to reimburse the customer?
01/04/2010
I am reviewing our compliance due to the recent reminder from FDIC via FIL-66-2009 regarding Disclosures at ATMs. Are we required to post notice on both the outside face of the physical ATM and on the screen? If so, must these notices also disclose the fee amount?
11/02/2009
I have been informed that a change to Reg E requires us to track every inquiry about an EFT. Is this true?
10/26/2009
Our signature card currently states, "The undersigned also acknowledge the receipt of a copy and agree to the terms of the following disclosure(s): Funds Availability, Truth in Savings, EFT, and Privacy." For certain products we require e-statements. We are considering modifying the signature card to include "e-statement agreement" as part of the list of disclosures they agree to and not require the customer to sign a separate e-statement agreement. Do you see any concerns with this?
10/05/2009
If a customer initiates a transaction online, then cancels it the same day or the day after, are we required to give provisional credit? The merchant has not promised a refund, but the customer has a print-out showing the transaction was canceled.
08/31/2009
I understand almost all of the consumer disclosure requirements do not apply to business customers. Would a sole proprietor or single member LLC be considered a consumer and receive a consumer EFT Agreement? We provide these business types a debit card in the individual's name.Are we required to provide business customers (corporations, partnerships, LLCs-with employees) with an EFT Services Agreement and/or an Agreement for Online Banking or Bill pay services?