Help. A few years back we began offering debit cards for customers to access their HELOCs. Now, the question has come up for error resolution, do unauthorized or fraudulent transactions fall under Reg E or should we be following Reg Z? Because the debit card only works on the HELOC, is it considered a credit card? We have a customer whose HELOC has been 'hit' by unauthorized use of the debit card.

If tied directly to the HELOC, it is a credit card. You also need to review your card issuing agreement as I believe VISA and Mastercard prohibition this on thier debit card product.

All I can say is, it must have an excellent track record if this is the first time you've had to think about it. (Hopefully it wasn't just done wrong in the past.)

Andy, we don't belive we issue too many of the HELOC debit cards. Thanks, all for the responses.

We have been offering HELOC cards for close to 6 years now it seems and I have never seen a complaint on one, too bad the rest of my card base isn't so well behaved.