If we receive a loan payment via EFT what are our responsibilities, if any under Reg E? We do not hold the deposit account from where the payment came. We also do not process the loan payment directly.
We are a non-profit (University). We do several ACH transactions on our checking accounts. Does Reg E or any other EFT Reg cover us in the event of fraud?
Is it mandatory to have a Complaint Policy for the bank? If so where can I find guidelines for the policy and procedures?
We have a customer whose boyfriend stole her debit card from her purse and used it at an ATM. The amount is $1,198.00 and our investigation company (Fiserv) said we are not entitled to chargeback, due to the fact that these transaction were PIN-based. Can the bank take back the provisional credit and still remain within the guidelines of the Reg E policy?
Is there a regulation that states that the point of sale terminals have to provide a receipt to the customer? Should this be a part to the EFT disclosures that are given to the customer?
A commercial customer opened a savings account for his commercial account. He was making too many over-the-counter withdrawals from this account monthly, so I (as the officer of the account) was told to close out his commercial savings account because he was violating REG D. Is this true? He only conducted OTC transactions, no EFT or ACHs.
Our stop payment forms for paper checks/ACH entries have the clause "an advance notice of three banking days is required prior to expected transfer date to fulfill stop payment requests." Is this stipulation a Reg or something we may have incorporated at some point?
I am reviewing our compliance due to the recent reminder from FDIC via FIL-66-2009 regarding Disclosures at ATMs. Are we required to post notice on both the outside face of the physical ATM and on the screen? If so, must these notices also disclose the fee amount?
When a customer writes a check to a third party and the third party electronically converts the check and it comes through as an ACH ARC transaction, shouldn't the bank treat these as checks and not ACH, if the system can distinguish these? Also, if the customer uses online bill payment and requests that a check be issued to a third party, should these be counted under the "6" or "3" rule? The request was made online, but a check is issued.
We have e-banking customers who do not want to get a paper or email statement because they view their account history online. Are we out of compliance if we stop sending email or printed statements?