Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network



May 28, 2015
Integrated Disclosures 101
Mary Beth Guard, John Burnett and Andy Zavoina

June 11, 2015
New Tech Advances to Improve Info Security
Susan Orr

June 22, 2015
50 Key Considerations for Integrated Disclosure Rules Readiness
Mary Beth Guard and Jack Holzkechnt

June 23, 2015
The IRS and TINs: The High Cost of Name Mismatches
Deborah Crawford

July 15, 2015
All About Escrows
David Dickinson



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

Registered: 03/04/02
Posts: 2325
Loc: The O.C., California
_________________________
I can explain it to you. I can't understand it for you.

Top
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: 31977
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)
_________________________
John S Burnett
BankersOnline.com

Top

Moderator:  Andy Z