Can you please help me think this through?

For a customer who wishes to have an ATM card on their savings account, could we issue them one of our Visa "Debit Cards", and simply restrict the use of it to ATM PIN transactions?

I don't believe there is a Reg E concern, but I'm not sure VISA would like us restricting the card in that manner.

Thoughts?

I can't address how Visa rules would inform the discussion, but I can offer some experience. There are a number of regional ATM networks that support PIN-based POS. Some will allow a savings account to be the primary account on an "ATM" card in the network; some won't. Find out from the regional networks you belong to whether a savings account as primary account will work in the network and whether it will also work in PIN-based purchases.

If you get that far, and learn the the cards would allow PIN-based merchant purchases, remember that those purchase transactions are among the transaction types that must be counted toward the FRB Regulation D savings account monthly limit of 6 transfers/withdrawals per month or statement period.

Thanks John!

Any thoughts from those well-versed in Visa operating rules?

Do you offer a specific card that is for ATM use only? Our institution has an ATM card that we'll issue on a savings account (and certain checking accounts) that isn't even branded with the MasterCard logo since it isn't a MasterCard debit card.

We've had this same question come up here mainly because Operations would like to not have the two separate cards any longer, and would prefer to just move to debit card only.

If we do this, while I think you certainly have the potential for more tracking in terms of Reg D transactions occurring on the debit card, I don't think there's anything from a Reg D perspective that states we cannot issue the debit card on a savings account. Like the other poster - I'm not sure though in terms of Visa rules.

Another question is whether or not it's an issue if we stop having ATM cards should we choose NOT to provide our Visa debit card then for savings and money market accounts since they are subject to the Reg D limitations? Again, I don't think it's a regulatory problem, but I can see where it might be a customer service issue. (On the other side of that, it's only about 400 customers who have those ATM cards right now.)

We also have a non-branded card in addition to our Visa debit cards. It used to be only ATM, but I added two PIN debit networks which provide fairly good coverage; one network even has an online PIN function with particpating e-Merchants. We only allow ATM withdrawals on Savings account and disable POS in the card set-up.

While most of our customers prefer the Visa debit card, it fills a need. The annual liscensing for the BIN is less then $100 per year, and there were no additional gateway fees for the networks because they're covered under contract for all of our BINs. I plan on keeping it unless there is an adverse ruling/change on the Durbin Routing provision which would require me to have both signature and PIN.