Can you please clarify the bank's responsibility and liability regarding Reg E compliance and MasterCard Zero liability related to business debit cards?
I wanted to get clarification on whether ACH debits were considered in the three or six limit, so I talked with the Director of Compliance for the Federal Reserve and she told me that ACH counts in the three limit along with checks, drafts, debit cards and similar orders to pay because of the convenience. Is that correct?
Our bank would like to pay $100 to every customer who opens a checking account and signs up for direct deposit. The incentive would be paid to the account upon confirmation of the service, which could be 30-60 days from account opening. In looking at the requirements of 217.101(b), I'm concerned that an examiner could argue that duration and minimum to open an account is a factor in the promotion. It goes without saying that an account would have to be established to hold the funds and I understand that direct deposit is an ancillary service. At the same time, the whole objective of the promotion is to get new customers and new accounts. Is this promotion risky from a compliance standpoint? Should we consider this non-employee compensation for IRS reporting purposes?
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.