We are trying to determine if on October 17 the VZL update will apply to PIN authorized transactions at point-of-sale. We have looked at Visa's International Operating Regulations and it doesn't address this.

Does anybody have definitive information from Visa that would answer our question?

I have not seen anything from Visa regarding zero liability. I know Mastercard issued their press release in May but did not provide specifics.

I have asked my relationship manager to follow-up with Mastercard for the specifics of their changes and requested they do the same with Visa. I have not seen a press release from Visa regarding changes to their program, though a vendor inquired on changes to our agreements as a result of (Visa) changes. I'm uncertain how they are concluding Visa has actual changes. Maybe Brian will see this post and opine in his infinite wisdom (yes, Brian paid me for that plug).

We just received notice from our VISA rep that the zero liability will to extended to ATM transactions using the Plus network.

The notice does not state anythings specific to PIN based transactions. My guess would be if they are not on the Plus network, then they are not covered.

Hopefully more information is released.

Thanks for the plug, acquiescent. The check is in the mail.

The current published edition available online of VISA's Operating Rules is dated October 15, 2013 so it is not reflective of any proposed changes.

I have heard from VISA bank's at the banking schools I have been teaching at say that VISA is extending coverage to Plus (currently PIN based transactions on the VISA network are already covered.) Since I do not have access to VISA bulletins, I don't have anything more definitive.

That is consistent with the info we received from our rep today. The zero liability is extended to the Plus network as well.

I guess seems relatively simple. I am assuming that since this change does not hurt anyone that no advance notice is required but recommended?

Basically, this means that VISA is extending Zero Liability to ATM withdrawals on its own network. (Note this would then not apply to ATM withdrawals using STAR, NYCE, etc.) No Reg E change notice is required. VISA issuers should update their terms and conditions to remove language that says that all ATM withdrawals are excluded from Zero Liability coverage and note the coverage for the Plus network.

Reading 1005.8(a) this doesn't look like a change that requires 21 days prior notice to existing customers. Am I correct that Reg E does not require notice after the change goes into effect either?

Even if there are no notification requirements under Reg E, does Visa require us notify customers of the change?

Thank you.

That's correct, banjo. Reg E doesn't require notice of a change that's favorable to the consumer. Visa has, I believe, also said that notice isn't required, but account disclosures need to be reviewed and corrected if necessary.

Thank you.

If you accept Interlink for "Visa Pin based" you should check the Interlink operating rules. They did change that the Interlink transactions are covered by zero liability a couple of years ago. If you are speaking of PAVD, I would imagine that should be in Visa International Op Regs for US somewhere. I can not imagine that Zero Liabiliity would be on all Visa Network transactions and NOT the PAVD. If not mentioned directly, since the PAVD are really on the regular Visa network, then these would be covered by zero liability the same as the sig based transactions.