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#1957930 - 08/28/14 07:01 PM ATM Cards to Debit Cards
terpsfan Offline
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We are replacing ATM only cards with check cards that will have POS capabilities. I believe based on the section below we need to provide Reg E disclosures. Would these disclosure be required in advance of issuing the cards?

Paragraph 5(a)(2)

1. One-for-one rule. In issuing a renewal or substitute access device, only one renewal or substitute device may replace a previously issued device. For example, only one new card and PIN may replace a card and PIN previously issued. A financial institution may provide additional devices at the time it issues the renewal or substitute access device, however, provided the institution complies with ยง 205.5(b). (See comment 5(b)-5.) If the replacement device or the additional device permits either fewer or additional types of electronic fund transfer services, a change-in-terms notice or new disclosures are required.

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eBanking / Technology
#1958406 - 08/30/14 12:29 PM Re: ATM Cards to Debit Cards terpsfan
Andy_Z Offline
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You are providing more access, new disclosures are required.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#1958407 - 08/30/14 12:31 PM Re: ATM Cards to Debit Cards terpsfan
Andy_Z Offline
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BTW, while your cite is correct, the cite itself is dated. Ensure you keep up with the changing regulations and aren't using an old resource.

http://www.bankersonline.com/regs/12-1005/12-1005-005.html

Try Alphabet Soup.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1958416 - 09/01/14 01:21 PM Re: ATM Cards to Debit Cards terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 2,058
can they be provided with the cards? or do they have to be provided in advance?

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