Besides the annual privacy disclosure are there any other disclosures required to be provided to customers annually?
We have the Regulation E Short error resolution notice on the reverse of our statement paper. We do not send an annual notice to our passbook account holders. Passbooks may receive a Direct deposit. Are we required to send a separate annual notice to these customers? Our auditors say we are. I thought passbooks were exempt from the periodic statement requirement and that the short Reg. E notice on the statement could be used in lieu of an annual notice.
Does an error resolution notice on the back of a bank statement make Reg E apply to commercial accounts, even though Reg E does not cover commercial accounts? Our bank statements are preprinted with this on them, and we use them for consumer and business accounts alike.
On the TruthInLending Disclosure that is signed at closing on a mortgage, is there a tolerance amount that is acceptable in case of any computing errors? If any errors are found, should a new TIL be signed?
I have a business customer who wants to dispute several transactions that were done with her visa/check card. I believe they don't qualify. The visa check card is in an individual's name, however it is hooked to a business account with an EIN #.
Regulation Z section 226.13 refers to a consumer's credit card or openend credit plan. The commentary makes it sound like the billingerror resolution notice is required for any openend plan but the notice set forth in Appendix G keeps referring to a credit card. Do we need to include the billing error resolution in the initial disclosure and an annual notice for a line of credit where there is no access card? If so, do we just delete the references to the access card and the $50 limit?
Is it possible use a debit card for withdrawals from home equity line of credit? If so, does Reg E apply and how do we disclose?
I have been approached by a customer who banks with another financial institution for information because they have not been recredited for forgery losses that they reported to their bank. Their question is... Is there a specific time frame that a bank must follow in recrediting a customer who submits an affidavit of forgery for a forged makers signature? I understand that the customer has one year to report the forgery unless the account agreements specify a different time period, but I am not aware of any banking regulation that states that the bank has to provide credit to the customer within a specific time frame. Can you help clear this up?
A customer revokes an ACH transaction claiming they had contacted the originating company to cancel any future transactions and the company did not cancel in time. Is this considered a Reg E error resolution claim? And, is the bank allowed to charge a processing fee for the revocation, similar to that of a Stop Payment Fee?