Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network



January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



Topic Options
#468149 - 12/08/05 07:35 PM Reg E vs VISA Error Resolution
Lee55 Offline
Junior Member

Registered: 04/28/03
Posts: 42
Please clarify my understanding for processing a verbal notice of a Reg. E claim on a signature-based VISA debit card transaction.

Our processor for VISA will not start an investigation until a customerís written notice is received from us (We do require written notice after receiving a verbal notice). Under Regulation E we have to begin our investigation from our customerís verbal notice. If we determine that an error did occur within 10 days, we would credit back the customer the amount of the unauthorized transaction (less the liability amount) satisfying our Reg. E obligations. When we receive the customerís written notice, we would forward it on to VISA for their investigation. If customer is provided zero liability we would credit back the customer (less the liability amount).

Top
eBanking / Technology
#468150 - 12/14/05 10:06 PM Re: Reg E vs VISA Error Resolution
Andy Z Online

10K Club

Registered: 10/27/00
Posts: 25296
Loc: On the Net
You are correct in that Reg. E doesn't allow you to require a written notice and that you must begin your investigation when you get the oral notice. Your clock starts at that time for Reg. E anyway.

I don't know that Visa allows your clock to start only AFTER you get a written notice. If it does, you're following those rules. If it doesn't, you need to follow the zero liability rules and the 5 day provisional credit rules Visa imposes and which you contracted for.

If you apply the Reg. E liability and then, properly following the Visa rules, determine that zero liability was applicable, a recrediting would be required. If the Visa rules do not allow you to require a written notice (forget about vendor requirements with your investigation vendor, focus on your agreement with Visa and with your customer) then you need to follow all the rules from the time of the notice, i.e. zero liability and 5-day provisional, when it is through their network.
_________________________
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

Top


Moderator:  Andy Z