11/03/2003
If a customer performs transfers between his MMDA and his checking accounts using the bank's "on-line banking" product and exceeds the preauthorized limit of 6 transactions, would he be considered in violation of the reg? I would think that because he is performing the transaction himself, it would not exceed the limit (similar to using an ATM card at an ATM machine). Have you heard anything from the regulators about this?
10/20/2003
With respect to Reg E disclosures, we will be offering online banking to our customers soon and I need to know if we need to re-disclose. (The service will be free of charge and our system will not offer bill pay. We will not open accounts online that will still be done in person. We will just be the account holding institution.) But, if I understand this correctly, we should edit our REG E disclosure to show this as a service we offer. Correct?
10/06/2003
We are just starting internet banking and our customers will have the capability to transfer funds from one account to another. Where do we stand with withdrawal limits with on-line transfers when we have savings accounts and Money Fund accounts? Are these calculated like telephone transfers?
06/16/2003
We are in the process of investigating Internet Banking and would like to know how transactions conducted through this product might impact Reg D transfer limitations. Are transactions done via Internet Banking considered to be "In Person"?
05/05/2003
An elderly, disabled customer gave his housekeeper his ATM card and PIN to make withdrawals enabling her to run errands, pick up medicine, groceries, etc. She helped herself to his account in the tune of $2,300 from January through March. He filed an ATM dispute in April. Is the customer fully liable for his loss?
04/07/2003
Can we offer debit cards to savings accounts customers? We would assume they would fall under Reg D. We are considering doing away with ATM cards
03/03/2003
We would like to confirm that a financial institution is not required to send receipts for Voice Response transfers.
02/17/2003
An issue has come up a couple times in the recent past: Our customers are sending emails directly to our employees, especially our commercial customers. The emails are not encrypted or password protected and they often contain non-public information - loan requests, updates on rent rolls, financial information on their company. Our customers want us to communicate in email form. We offer email that is encrypted via our Internet banking product. However, the lenders are telling me that their customers will not go through the inconvenience of logging in to Internet banking to communicate. Our Privacy Policy does extend beyond the minimum requirements of GLB; we opted to include commercial customers under the privacy blanket. Our E:Banking Policy does not address communication of non public information via email (incoming or outgoing). Does anyone have a practical solution to this growing concern?
08/05/2002
If a transfer is conducted through on-line banking product, does the periodic statement requirements (205.9) of Reg E apply?
08/05/2002
We have a customer who primarily uses the internet and wants to stop his paper statement. We don't offer the electronic statements yet, but is there something prohibiting us from canceling his monthly paper statement?