Most Popular Technology Content
Representative Payee Debit Card
08/20/2007
I received a debit card application from a representative payee for an account owner. I think we can issue one, what are the risks involved?
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?
EBT Card Surcharging
08/13/2007
What are the rules about surcharging a EBT card in Massachusetts? As long as the user can opt-out of the charge it should be allowed, I would think. At one time there was talk about including the surcharge in the allotment.
No Provisional Credit - No Real Proof Needed?
08/13/2007
In Sec 205.11.3.c.2.i of Reg E, if a bank officer decides not to give provisional credit to an account because they feel there wasn't any error or unauthorized transaction and basically the consumer is not being truthful, can the officer decide this without any real proof? If yes, what does "reasonable basis" mean?
Stolen Debit Card - PIN Written on Checkbook
08/13/2007
We have a case where a customer's purse was stolen including her debit card. The customer has stated that her PIN number was written in her checkbook resulting in numerous ATM withdrawals by the thief. What are the responsibilities of the customer vs the bank in this situation?