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March 24, 2015
Maze of Debit Card Compliance
Brian Crow

March 25, 2015
Appraisals and Evaluations: Performing Internal Compliance Reviews
Eric Collinsworth

March 30, 2015
Cybersecurity: Third Party Resilience – What the FFIEC Wants You to Know
Susan Orr

April 2, 2015
Fair Lending Hot Topics – Don't Get Burned!!
Patricia Cashman

April 7, 2015
Building a BSA Training Program
Deborah Crawford

April 8, 2015
Advertising Compliance
David Dickinson



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#1668685 - 02/23/12 08:51 AM Reg. E-Error Resolution
Cale_N_Oats Offline
Platinum Poster

Registered: 08/14/08
Posts: 742
Loc: Southern Illinois
We were alerted by a service provider of some unusual debit card activity on a customers account. We sent a letter to the customer asking if these charges were legitimate. They replied back that they were not and we began the error resolution process. The commentary on Reg. E says that the consumer liability rules do not apply when the bank identifies the error and corrects it on its own. My question is when does the bank cross the line from correcting it on it's own to correcting the error when notified by the customer?

I would say that since we contacted the customer and they verified that the transactions were invalid then Reg. E would apply.
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eBanking / Technology
#1668843 - 02/23/12 10:50 AM Re: Reg. E-Error Resolution [Re: Cale_N_Oats]
Matt_B Online
Diamond Poster

Registered: 09/06/11
Posts: 1428
Loc: A CU, Where Regs Don't Apply
"do not apply when the bank identifies the error and corrects it on its own"

Just based on that statement, I would say it does still apply. It wasn't corrected on its own, the customer had to request it be corrected, though the conversation was initiated by you.

I think the identified and corrected on its own would be more in the case of a vendor double-posting and things such as that.
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#1668921 - 02/23/12 11:56 AM Re: Reg. E-Error Resolution [Re: Cale_N_Oats]
Cale_N_Oats Offline
Platinum Poster

Registered: 08/14/08
Posts: 742
Loc: Southern Illinois
That's what I figured too Matt. Thanks
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