In the case of an unauthorized debit entry, does the bank have to give immediate credit to the customer?
Is there any difference between and EFT item and an ACH item?
Can the bank require a customer to contact the merchant directly regarding EFT disputes as part of the investigation process, specifically POS/debit card transactions?
We are starting up a new debit card program. I need help on what policies I need to make sure that I include in our debit card program. Prior we only offered ATM cards. What disclosures do I need to be mailing out? I figured I needed to mail out new EFT disclosure and Reg E disclosure. What kind of offline limits do I need to set for our customers? Is there a Regulation on that?
Does the following safe harbor also apply to identifying recurring check card debits vs. one time check card debits for the purposes of the customer's right to stop payment? Fed Commentary for Opt in 1005.17 ii. Coding of transactions. A financial institution complies with the rule if it adapts its systems to identify debit card transactions as either one-time or recurring. If it does so, the financial institution may rely on the transaction's coding by merchants, other institutions, and other third parties as a one-time or a preauthorized or recurring debit card transaction.
Is there something in writing from the Federal Reserve and/or the CFPB that supports the comment in this<a href="http://www.bankersonline.com/operations/guru2012/gurus_op011612a.html "> Q and A</a> on Reg E periodic statement requirements? The Iowa Bankers Association, our compliance liaison from the Federal Reserve, and all other sources I can find seem to disagree with this point of view. They say the IF an account CAN be accessed by an EFT, regardless of whether it actually is, that at a minimum quarterly statements have to be provided (and also for each month when an EFT occurs).
We are changing our debit cards from Visa to MasterCard. Do we need to send a new EFT disclosure?
We have several accounts that are set up to receive their Checking Account Statement (Paper) Annually. Are we out of compliance by not sending them a statement monthly when our disclosures state that they have 30 days from the date the statement was made available to us to notify us of any errors?
In most cases, when an EFT error (ACH) is reported to us, the investigation is initiated immediately and completed within 10 days. Our bank requires written confirmation for all EFT errors that are reported. We realize that without written confirmation, it does not delay the initiation or completion of the investigation. However, what are our requirements for crediting if the customer does not give us written confirmation within 10 days? Do we have to follow the provisional credit rules? Or do we just let the reported error “hang” until we get that written confirmation?
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.