01/19/2009
Is the bank responsible for unauthorized transactions that occur up to 60 days from the mailing of the statement containing the first error and unauthorized transactions within the last 60 days from the date of the notification with the customer being responsible for the transactions occurring in between regarding untimely notice by the customer?
11/24/2008
A customer was incarcerated in jail on Feb 28, 2008. She called the bank on April 9th to change the address on an account and is informed of checkcard transactions she claims she did not do (transactions are Feb-April). The customer states she does not want to dispute the transactions until a later time. It has now been 7 months and the customer would like to dispute the transactions now. What are the guidelines for the bank since the customer was informed of the transactions seven months ago and chose not to do anything at that time?
11/24/2008
I know that Reg E excludes wires and specifically telephone-initiated wires. How about wires initiated through an on-line banking system? Are they also excluded from Reg E?
11/17/2008
I'm not sure if we have crossed any compliance or legal lines by allowing the following with regards to online banking access. A customer is both an officer and an authorized signer on a business account, either a corporation or LLC. This person also has a personal DDA account with the bank. The customer has applied for and been granted access to view his business account via our online banking product. The same customer also wants to view his personal account via online banking, but he does not want to have a separate access ID and password for the personal account. To honor the customer's request we have granted viewing privileges to both the business and personal DDA accounts under one access ID and password. Can you tell me if we have entered a gray area by doing this? Should the bank insist on keeping business and personal accounts separate in online banking by having different access IDs for both types of accounts?
11/10/2008
When a Reg E claim is received which consists of several transactions at various merchants, is the claim settled and responded to after the last one is investigated and finalized or as each transaction within the claim is investigated and finalized?
11/03/2008
We had approved and closed a Reg E claim prematurely and the merchant later represented with a copy of a receipt that bears our cardholder's signature. Can we now reverse our decision and debit the client's DDA? If so, do we have to send a new resolution letter?
09/22/2008
If a customer contacts the bank stating there has been ACH transfers coming out of their account that they never authorized. Would the bank be required to resolve the problem by following Sec. 205.11 of Reg E - Procedures for resolving errors?
09/22/2008
Does the bank have to provide a notice outlining the action taken and/or results of the investigation as Reg E requires on debit card disputes when a customer reports an ACH transaction as unauthorized or disputed?
09/15/2008
Under Reg E, there is an exception for account to account transfers associated with a customer agreement. However, I don't read this to include customer-initated intra-institutional transfers, e.g, I transfer from my savings to my checking one time. Are those covered?
07/14/2008
A debit card was stolen and used at an ATM with the PIN number. Is the customer liable for the $50?