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April 16
Handling ACH Origination Exception Issues
Shelly Simpson

April 17
Fair Lending - Internal Monitoring
Patricia Cashman

April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht



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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: 738
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 Offline
Diamond Poster

Registered: 09/06/11
Posts: 1128
Loc: Iowa
"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: 738
Loc: Southern Illinois
That's what I figured too Matt. Thanks
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