We have a customer that is disputing a debit card entry. She closed her account with us before she disputed the entry. Are we liable to return her money?
What information has to be disclosed on the back of a savings statement?
Is it mandatory to have a Complaint Policy for the bank? If so where can I find guidelines for the policy and procedures?
We offer e-statements to customers. When someone signs up, he is provided the Reg E disclosure electronically at that time. Do we need to have a link to the disclosure for future reference, and specifically, the Reg E part of reviewing a statement for errors? Would a link be sufficient for people to access at any time if the language is not included on each statement?
Does Reg E allow us to deliver the required notification letters via email?
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?
I work for a third-party service provider for financial institutions in the compliance area for credit cards. I am trying to get my hands around a procedure due to non-compliance and there is no definition of POS that I can find. The problem is that I am fighting with the manager regarding the error resolution 45-day requirement vs the 90-day requirement. She is telling me that everything we do is POS and I need to verify that. My thoughts about a POS were that it was always a pin-based transaction and if you use your debit card as a credit card through Visa or Mastercard it falls into the Reg Z realm. Can you help me with this?
Reg E Commentary 205.11(a)-4 requires banks to comply with error resolution procedures for claims on closed accounts. However, Reg E does not provide guidance on how to provide provisional credit in such cases and 205.11(c)(2)(i) indicates crediting customer's account. Our thoughts are to credit another account owned solely by the customer and if no such account exists, to ask the customer for direction on providing provisional credit. If a customer requests a check in the amount of the credit, is a bank required to deliver a check since this provisional credit cannot be reversed as provided by 205.11(d)(2) if the claim is denied?
Since we cannot require employees to accept e-statements for their deposit accounts, we are trying to develop incentives that will highly encourage them to sign up for the e-delivery. Presently, employees are not charged a service charge for their accounts. Can we change this policy for existing and future employees, so they will receive an account free of charge if they use e-statements? Otherwise they will be charged the normal service charge incurred by customers without violating regulations, thus start assessing a service charge on all existing employee accounts unless they sign up for e-delivery.
Are we required to send out a yearly savings statement? We know we have to send the monthly statements that have electronic items, but how about the rest?