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#579895 - 07/06/06 02:42 PM Debit Cards & Commercial Customers
bankauditor Offline
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Joined: Mar 2006
Posts: 19
I know that Reg E doesn't apply to commercial customers, but is anyone aware of any disclosures that are required when a commercial customer contracts for a debit card? Can we do strictly an application with no disclosures?

Thank you!

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#579896 - 07/07/06 04:23 PM Re: Debit Cards & Commercial Customers
bankauditor Offline
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Joined: Mar 2006
Posts: 19
bump...does anyone give commercial customers any disclosures?

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#579897 - 07/07/06 05:54 PM Re: Debit Cards & Commercial Customers
Gotwood Offline
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Joined: May 2001
Posts: 715
We do, it is similar to our consumer disclosures, but doesn't get into the consumer liability issues.

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#579898 - 07/07/06 06:20 PM Re: Debit Cards & Commercial Customers
bankauditor Offline
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Joined: Mar 2006
Posts: 19
Thank you!

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#579899 - 07/07/06 09:36 PM Re: Debit Cards & Commercial Customers
Andy_Z Offline
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You may want to define "disclosures" as you should certainly be defining the terms of use/agreement in some document. I'm not sure if V/MC has a separate list of terms you must provide or not, if you have an affiliation with them.
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#579900 - 07/07/06 10:10 PM Re: Debit Cards & Commercial Customers
Darkhorse Offline
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Joined: Nov 2004
Posts: 501
out of my mind
We have them sign a little application that also makes them state that they are aware that they are not covered by the protection of Reg E, blah, blah, blah.
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#579901 - 07/07/06 11:24 PM Re: Debit Cards & Commercial Customers
Midwest Banker Offline
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Joined: Nov 2004
Posts: 349
Cheeseland
I believe MC now requries zero liability even for business cards in cases of theft, something they did not do before. The date change was March of this year?

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#579902 - 07/10/06 09:11 AM Re: Debit Cards & Commercial Customers
VT Banker Offline
Member
Joined: Sep 2001
Posts: 70
VT, USA
VISA also has the same ruling for commercial cards and zero liability but states itonly covers those transactions processed through the VISa network.

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#579903 - 07/10/06 07:35 PM Re: Debit Cards & Commercial Customers
Compliancer Offline
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Joined: Jan 2006
Posts: 334
San Francisco, CA
You must at least disclose the association programs associated with the card your bank issues, including the Zero Liability Policy.
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#579904 - 07/13/06 04:58 PM Re: Debit Cards & Commercial Customers
Diana Timberlake Offline
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Diana Timberlake
Joined: Apr 2002
Posts: 118
Is anyone willing to share what they are providing the customer since the no liability changes went into effect? If so I will provide my email address.

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