01/31/2005
I've read your articles on Reg. E Disclousres on the Web. But we are taking applications for Internet banking via the Web. Do we still need a Reg. E Disclosure and what should we be sure to include and watch for?
01/17/2005
Our bank has heard that NACHA is going to start imposing a $18.00 fee for every unauthorized payment transaction processed. Is this true and if so do you know when it will go into effect?
01/17/2005
I have been told that the employees in charge of on-line banking are considering allowing wire transfers through our new on-line banking product. What kind of compliance and security issues should they consider when they are designing this product? We are new to on-line banking so my feeling is that we should learn to crawl before we run. Some of the bigger banks do not have this on-line banking feature. How does our midsize bank think they have the resources and the knowledge to accomplish this?
12/01/2004
The companies that provide bank technology are developing ways for bank customers to securely automate the process of exchanging data without using dedicated modems, TTY transfer or physical exchan
11/01/2004
Our bank is considering converting the ATM cards connected to the checking accounts of current customers into Visa debit/check cards. Would this be considered a substitution or renewal of a solicited card or must we follow the rules for an unsolicited card?
10/04/2004
I am conducting an internal audit for a financial institution on Reg E - Electronic Fund Transfer Act. In 205.10(e)(2), it states that no financial institution or other person may require a consumer to establish an account for receipt of electronic fund transfers with a particular institution, as a condition of employment or receipt of a government benefit. I interpreted this that a financial institution cannot require a new employee to establish an account in order to receive a paycheck. Is my interpretation correct?
10/01/2004
Regulation E is one of the older consumer protection regulations on the books. It dates back to the 70's. Except for a few issues, it has not seen significant change for decades.
09/20/2004
Our teller program has a transfer option. If we have a customer making a deposit with an onus check from another account holder, is there any regulation that would prevent us from processing the transaction as a transfer rather than a straight deposit?
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".
05/17/2004
Do ACH transactions include wire transfers and EFTs?