12/17/2007
The passage below is part of John Burnett's response to a Reg E question concerning unauthorized transactions reported beyond 60 days from the statement delivery date. For example, if there was an unauthorized transaction (no access device used) that appeared on the customer's June statement and he or she is just now reporting it, must the bank reimburse the customer? My bank has been denying these claims as too old. Based on everything I've read, I believe the customer is not liable for these initial transactions, even though they appear on earlier statements. I am wondering what John meant by "unless the transaction is one in a series" in the article below. Could someone elaborate please? Your consumer/customer is entitled to enter a claim with you that an entry was unauthorized at any time (the 60 day limit in section 205.11 only covers the customer's right to the procedures in that section, not the customer's liability for unauthorized transfers, which is found in section 205.6). If the transaction is unauthorized, the customer is entitled to a refund unless the transaction is one in a series and took place more than 60 days after the statement was available that showed the first unauthorized transaction in the series.
05/28/2007
When a bank owned ATM gives approval for a cash withdrawal transaction on a credit card (not a debit card), but no money was received and the amount shows as a charge on the credit card, who is responsible for filing the report and/or correcting the error?
03/12/2007
We have been told that some banks are reducing the number of days that a customer can report an error concerning an EFT from 60 days to 30 days. Is this permissible, or is it a violation of Reg E?
11/20/2006
Does it matter if you "report" error resolution investigation findings, provided that an error did occur, to the customer via phone or mail?
03/06/2006
On Visa's website under Zero Liability it states that financial institutions may impose greater liability on the cardholder if the financial institution reasonably determines that the unauthorized transaction was caused by the gross negligence or fraudulent action of the cardholder -- which may include the customer's delay for an unreasonable time in reporting unauthorized transactions. We have a cardholder with unauthorized transactions. I can see that she did a balance inquiry with her card at our ATM five days before she notified us that there was a problem with her account. At the time of the inquiry she was overdrawn and over $800 in unauthorized transactions had occurred. She is negligent in not reporting the issue sooner. By following Visa regulations is she liable for any transactions that occurred after she noticed the balance was not correct at the ATM?
06/06/2005
Does it matter if you "report" error resolution investigation findings, provided that an error did occur, to the customer via phone or mail?
05/23/2005
We have a POS and LOS system for our mortgage applications. My question is, if a Member starts an application on the website, runs a credit report but closes out of the system before they have finished the input and the Desktop Underwriter doesn't make a credit decision, does this loan have to be submitted to HMDA? It can't be pushed to our LOS system without the DU response and is considered an "unsubmitted" by our company. Please advise.
12/06/2004
What are the restrictions and/or liability regarding a bank offering debit cards to businesses? What is different from marketing this product to consumers?
08/02/2004
How will float days be determined on imaged items?
08/02/2004
How will float days be determined on imaged items?