Most Popular Technology Content
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?
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?
ACH Debit Card Compliance
08/20/2007
Can you provide insight into what regulatory impact, if any, is associated with ACH debit cards? For example, does this product fall under Reg E compliance?
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?