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September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 24
Using CPTED to Make Our Banks Safer;
Dana Turner and Carol Dodgen

September 30
Revised Escrow Rules - Review and Update;
Jack Holzknecht and Mary Beth Guard

October 7
CRA - Digging for Credit;
Patricia Cashman

October 8
Applicants and Applications: Knowing the Players and the Rules;
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#1539885 - 04/22/11 04:12 PM Banks sued for lack of signage
califgirl Offline
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Registered: 03/04/02
Posts: 2255
Loc: The O.C., California
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I can explain it to you. I can't understand it for you.

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eBanking / Technology
#1540015 - 04/25/11 08:45 AM Re: Banks sued for lack of signage [Re: califgirl]
John Burnett Online
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Registered: 10/27/00
Posts: 30417
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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