We are starting a business debit card program. While working on our disclosures we have come across something we're not sure how to address: business customers who request to have personal accounts linked to their business debit cards. Is this a permissible practice, and what are some liabilities facing us in such a situation?
Can you provide insight into what regulatory impact, if any, is associated with ACH debit cards? For example, does this product fall under Reg E compliance?
What is our liability if we issue a debit card to a business customer? If our card has a MasterCard logo, do we have to go by MasterCard rules? Are we in violation of any Regulation if we disclose to the customer that they will take all the liability?
Can we issue debit cards to savings account holders? The account will not be a transactional account. We would only allow pinned transactions on these cards.
The Fair Credit Reporting Act section 605(g) says no more than last 5 numbers of the card number may be printed on receipts or the expiration date. We just had a new Cash Advance machine put in use. It truncates the account number but still prints the expiration date. It seems the machine will be in violation if the expiration date remains on the receipts. Is that correct?
In the most recent Consumer Advisory Council meeting at the Federal Reserve, one of the topics of discussion was consumer protections for payroll cards.
The Federal Reserve tracks interesting information such as how much money is moved by checks and how much by electronic transfers. In the world of electronic payments, the watershed has happened.
We have recently started issuing debit cards and are not sure which "notice of action taken" should be used when a customer is declined a card. We have different types for loans and deposit products. Which should we use?
Congress has asked the Federal Reserve to study the disclosure of fees imposed by account-holding institutions on debit cards issued to consumers.
Our internal auditor states that we should be sending a Notice of Adverse Action for denied ATM and debit cards. Is this a requirement of the Fair Credit Reporting Act?