09/06/2004
I am currently printing verbiage on the face of checks that I write specifically stating that the payee is NOT authorized to initiate an EFT for payment of a check and the check may not be electronically converted. I am also stating on the face of the check, under the check number, that the serial number is not valid for electronic check conversion. After studying 12 CFR 205 (FRB Regulation E) it seems as though this is the my only chance as a consumer to prevent this practice. What is your opinion? Is the front or back of a check the correct place to put any authorization or conditional information?
06/21/2004
Currently we generate periodic (monthly) statement on any passbook account that has had an EFT credit (debits are not allowed) during the month. Is this necessary? Secondly, do we need to send an annual error resolution notice to those passbook account holders who have not had any EFTs to the account during the year?I am confused by the language in 205.8(b) which states "any account to or from".
06/07/2004
Do return (chargeback) ACH transactions have to be broken down individually (online or on consumer statements) or can the multiple returns be sent back to the originating deposit system and on the customer statement as an aggregate (total of all returns) return amount?Does Reg E cover commercial accounts or only consumer?
05/17/2004
Do ACH transactions include wire transfers and EFTs?
05/03/2004
A mother gives a son her ATM card and her PIN to use. The son and his wife steal the card a week later and over the weekend withdraw $951.00 from the mother's account. The brother, who is not on the account calls to report the card lost and the card is placed on hot card status. The CSR is a neighbor and insists we give her money back immediately. Does the bank have any basis for not returning the money when according to REG E it was reported within the time frame? Is there any way that we can use the fact that we were told that the mother had previously given the son her card and number? Where can I find more information concerning the liability of the bank in such cases?
03/01/2004
We do not open accounts online. The Reg E disclosure on our Bank's Web site covers the types of transfers that are allowed for Online Banking along with fees, documentation, Financial Institution's Liability, Confidentiality, Unauthorized Transfers, Error Resolution Notice, etc. (i.e., things we don't need), but this disclosure does not include other EFTs, such as check conversion. Is it required here? The Reg E disclosures provided to customers other than on the Web (new account, debit card application, etc.) do include that type of EFTs.
03/01/2004
I have a customer who has unauthorized transactions on his checking account which go back to Jan. 2003. He just notified the bank on 01/22/04 that he became aware of the unauthorized activity in Oct 2003. The customer knows that a family member performed the unauthorized transactions. Under the circumstances, is the bank responsible for the losses? The customer did file a police report, but is hesitant to file a criminal complaint or press charges. He wants to recover the loss from the bank.
03/01/2004
If NACHA's 60 day rule only applies to consumer accounts for EFT unauthorized returns, how do we proceed on business accounts?
02/16/2004
Do you have any information regarding discontinuing printed and mailed bank statements in favor of electronic delivery of bank statements? We have online bank statements and a customer has asked us to discontiue mailing them out to her. What do we have to do?
02/02/2004
Can a customer waive his Reg E rights? We have customers who do not want to receive a monthly statement, even though they have electronic transactions that are subject to Reg E. The customer is able to view their account history via our Online Banking product. Must we send them a paper statement?