I am needing input from other banks. Do you impose the consumer liablity as defined in 205.6 (b)?

I am talking about the $50.00/$500.00.

We are just wondering what others are doing.

I know of no banks that don't impose maximum liability when they can. Many Reg E issues are related to debit cards however and the VISA/MC no liability rules will sometimes trump Reg E.

And remember, of course, that state law trumps Reg. E liability limits if it is more protective of the consumer.

the financial institution that i formerly worked at did not impose the liability on a regular basis. they were a 42-branch, $2.5 billion dollar bank.

Thanks Houri!! This is what I am looking for more branks to say what they are actually doing as opposed to what the REG states we can do. I have not been in the REG E world for about 4 years, but I know when I was and I went to seminars none of the banks present were making customers liable for any amount (in reference to PIN transactions)

Do you know if California has a state law that does this?

This is JUST a guess, but my guess is it does not. I know that there were times when we did impose liability for justified reasons.

I guess I should have phrased my response to indicate that the 30-40 banks that I have either worked for or performed compliance reviews for, all imposed maximum liability on customers when allowed under the Regulation E, State law, or card issuer's agreement.