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#1158102 - 04/06/09 02:17 PM Proposed Reg E Debit Hold Prohibition
mgs41 Offline
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Joined: Jan 2007
Posts: 167
Our bank is considering deducting signature-based authorizations from the customer’s Deposit system available balance at the time of the authorization. As I understand it, this would be placing a hold on funds. Would this be prohibited in some circumstances under the Proposed Reg E changes? I guess I'm confused about whether POS counts in the Reg E definition of a "debit card transaction". Thoughts?

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eBanking / Technology
#1158617 - 04/06/09 08:37 PM Re: Proposed Reg E Debit Hold Prohibition mgs41
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
POS most certainly counts as a debit card transaction. In fact, it's the lag-time built into signature authorized POS transactions that has the regulators so exercised on the question. Holds aren't attacked in the proposals, though. What is attacked is the assessment of overdraft fees triggered exclusively by a hold when the hold is greater than the final transaction (if the actual transaction would not have triggered the fee on its own).
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#1159644 - 04/08/09 01:36 PM Re: Proposed Reg E Debit Hold Prohibition John Burnett
mgs41 Offline
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Joined: Jan 2007
Posts: 167
Thanks again John.

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