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December 3, 2014
Overdrafts: Latest Regulatory Feedback, Guidance & Best Practices Webinar
David Dickinson and Jerod Moyer

December 4, 2014
Freebies, Bonuses and Contests
John Burnett and Andy Zavoina

December 9, 2014
Bankruptcy: Creditor Do's and Don'ts
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December 10, 2014
Branch Audits: What Is Going On Out There?
Patricia Cashman

December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett



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#1539885 - 04/22/11 04:12 PM Banks sued for lack of signage
califgirl Offline
Diamond Poster

Registered: 03/04/02
Posts: 2285
Loc: The O.C., California
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eBanking / Technology
#1540015 - 04/25/11 08:45 AM Re: Banks sued for lack of signage [Re: califgirl]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30863
Loc: Cape Cod
Defensive strategies:

(1) Make sure that the notice required by Regulation E 205.16(c)(1) is posted on or at the machine. Take a dated digital photo of the notice and machine and note its location. If your camera provides GPS location position info, make sure that's recorded, too. If a sign is defaced or removed by someone other than the ATM owner (a vandal or one of these opportunist plaintiffs, for example), the Electronic Fund Transfer Act provides a safe harbor, but you have to document that the notice was actually posted to get it.

(2) Make a check of the notice a priority item on the ATM servicing checklist. Have its presence documented each and every time the machine is serviced. If the notice is missing, get someone to replace it ASAP. Document that it is again posted (see item (1)).


Edited by John Burnett (04/25/11 08:45 AM)
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