11/26/2012
We have a customer who went online and provided his card number for a service and after the fact felt that it was a fraudulent website. Since he did in fact authorize the transaction I believe that this would not fall under Reg E error resolution process. What are your thoughts on this?
09/10/2012
Reg E - crediting interest in error resolution: Part 1005.11(c)(2) = Forty-five day period. If the financial institution is unable to complete its investigation within 10 business days, the institution may take up to 45 days from receipt of a notice of error to investigate and determine whether an error occurred, provided the institution does the following: (i) Provisionally credits the consumer's account in the amount of the alleged error (including interest where applicable) within 10 business days of receiving the error notice. Examiners have never criticized this before, but we haven't been crediting interest back on the amount of the dispute. Does everyone really do that? The interest is only mentioned in the 45-day rule, so if we give credit within first 10 business days then no interest credit required?
08/29/2011
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?
05/02/2011
What information has to be disclosed on the back of a savings statement?
01/17/2011
Is it mandatory to have a Complaint Policy for the bank? If so where can I find guidelines for the policy and procedures?
12/06/2010
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?
11/15/2010
Does Reg E allow us to deliver the required notification letters via email?
10/18/2010
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?
03/16/2009
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?
03/02/2009
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?