Most Popular Technology Content
Corporate Debit Card Disclosures
08/27/2007
We are considering offering a debit cards to our corporate accounts, what type of disclosures will be needed?
Reg E - Stolen Debit Card
08/27/2007
We have a customer who gave out his debit card PIN to his caregiver so that the caregiver could make withdrawals on behalf of the customer (the customer was always present at the time of withdrawal). The customer's card was stolen and then used at an ATM for 2 unauthorized withdrawals. Are we obligated to return the funds to the customer? Does Reg E protect the customer even though he gave out his PIN?
Debit Card Transaction Time Limit
08/27/2007
How long after a debit card transaction does a merchant have to send it through? Is there a time limit at which it will no longer be valid?
Electronic Right of Offset
08/20/2007
Our lending operations department (not credit card) would like to initiate an EFT through our third party vendor to debit our customer's deposit account to exercise our right to offset for amounts owed on our customer's loan. Our deposit account terms and conditions discloses our right to offset any amounts owed to the bank. We know that generally Reg E, Section 205.3 (c)(5) would allow the bank to electronically transfer funds between a customer's accounts without the customer's specific request under certain circumstances and that the official commentary provides that this exception to Reg E includes the right to initiate "electronic debits or credits to consumer accounts for check charges, stop-payment charges, NSF charges, overdraft charges, provisional credits, error adjustments and similar items that are initiated automatically on the occurrence of certain events." In order to exercise our right to offset electronically, the transaction will need to be processed through our third party vendor. Do we have any Reg E or other regulatory concerns in doing so?
Selling in a Crowded Market
08/20/2007
As more financial institutions enter the market, what is the best approach to prospecting and selling Remote Deposit Capture to your customers?