Vendor Guru Q&A - Compliance

Latest Compliance - Transfers Topics

Reg E Telephone Transfers/Transactions

07/25/2021

I have a question about telephone transfers. The telephone transfers we perform are for the customer who calls the bank and requests the teller to withdraw from one account and transfer funds to another account. We currently have a custom form that a customer signs to perform ongoing telephone transfers and we keep this on file authorizing the bank to perform these transactions. We would like to discontinue using this form. Is this old form necessary and is it even a compliance requirement under Electronic Fund Transfer Act? We currently document on the transaction ticket "Telephone Transfer per Customer request". Any advice or information would be greatly appreciated.

Popmoney Considered Automatic Transfer? (Reg D)

07/01/2018

Is Popmoney considered an automatic transfer with regards to Reg D (excessive withdrawals) limitations?

Client Sign New AFT if Change in Payment? (Reg E)

04/02/2017

Do we need to have the client sign a new Automatic Fund Transfer (AFT) form if we are changing how their payment will be applied? i.e. from P&I payments to P&I with the surplus funds being applied to principal only. The amount would not change, only how it is applied.

Is signature needed for OD transfer service?

09/25/2016

Is signature needed for OD transfer service? Our "overdraft" product does not qualify as overdraft under 12 CFR 1005, as it's simply a transfer between the consumers accounts. The consumer receives two free transfers per year but is subsequently charged $0.50 for each transfer thereafter. Is the consumer's signature required to link his/her deposit accounts for this "overdraft" service?

FDIC Insurance Apply to Cyber Crime Loss of Funds?

05/06/2013

I had a customer ask if FDIC insurance coverage would apply to Cyber Crime loss of funds. Thoughts?

Reg E Periodic Statement Requirement

04/29/2013

Is there Reg E periodic statement requirement for retirement savings accounts where we set up a preauthorized debit from a customer's account at another institution to be deposited to a retirement savings account at our institution? If so, what is the requirement? These deposits are not payroll deposits but just periodic deposits (i.e. monthly deposits of a specified amount) to a retirement savings account.

Request OD Protection Again After Reg D Violation

04/01/2013

A customer's savings account is set up to protect his checking via overdraft protection and he has violated Reg D for three consecutive months and the bank has removed the overdraft capability, following all requirements of course. When can he or can he request overdraft protection from his savings to his checking again?

Dispute Online Charges Purchased By Minor (Child)

04/01/2013

Our customer gave their 9-year-old child permission to buy a book on the Internet through Apple ITunes in the amount of $9.99. While in the website the child was looking at a lot of other things. Next day 12 charges came through their account totaling $373.44. They want to dispute as they only authorized $9.99. When they talked to the child he said he looked at lots of stuff but had no idea he was purchasing what he looked at. The parents called the number on statement and it directed them to a website which they emailed. We told them to let us know when they hear back which could be 48 hours. Can they dispute the difference?

Difference Between EFT Item and ACH Item?

02/25/2013

Is there any difference between and EFT item and an ACH item?

Visa DC Dispute-Time Frame for Each Company?

02/18/2013

Visa debit card dispute. A customer just noticed transactions that posted to their account. The customer is disputing three different companies. Do we figure the time frame each merchant? Or would the liability be on consumer because they did not notify us to block their account on the first transaction?

Premium Content View All

International Remittance Transfers for PayPal Customers

Question: Regarding the International Fund Transfers Rule, we have many customers that use PayPal and many of these debits are sent overseas.

UDAAP Settlement

It isn't only the big banks and it isn't only the CFPB. The FDIC has announced a settlement with Citizens Bank of Pennsylvania for deceptive practices that violate the FTC Act.

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Reg E Fraud- EFT Claim for Cash App

07/25/2021

During a review of the account, we noticed several transactions to Cash App, to the same people from last December and one in January. These were NOT disputed. Should we inquire about these transactions? If so, could we start our calculation from the statement date (plus 60 days) from the statement with the first unauthorized transaction? Does it make a difference that the December, the May and June transactions were on different cards? (The customer has had multiple cards.)

ACH Return for Unauthorized Debit

07/25/2021

Can a customer initiate an ACH Return for unauthorized debit from a closed bank account?

Reg E Telephone Transfers/Transactions

07/25/2021

Latest Compliance - Transfers Topics

Pages

Pages

Pages

hot right now