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Latest Compliance - Transfers Topics

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?

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?

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?

Reg E Cancelled Recurring Transactions

12/10/2012

June 15, 2011 titled Debit Cards - Error Resolution Problems Solved. In that training, there were slides on cancelled recurring transactions that stated that these types of transactions were not covered by Reg E. Could you please provide the reference in Reg E where it supports that a transaction that occurs after the recurring transaction is cancelled is not considered unauthorized and therefore not covered by the regulation.

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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.

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Protected Funds Apply to Child Support Levies?

04/14/2019

I recently did an e-train webinar, regarding California Levies/Subpoenas as my credit union is located in California and Oregon. In this e-training the instructor told us that protected funds do not apply to child support levies. I have been to many seminars regarding levies and subpoenas and I have never been told this. I was taught of course that IRS levies do not apply to protected funds, but never child support. Does this rule only apply to California or to all states?

Reg E Unauthorized Transaction w/PIN Issue

04/14/2019

REG E, if a consumer has given his or her PIN to a friend, the friend later steals the card [and uses it without authority], are we required to give them their money back under Reg E?

Family Trust-Individuals Use Separate SSANs?

04/14/2019

John and Cindy both have individual accounts and just created a family trust which has no tax number. Can they use their separate SSANs for the account without adding the other person as joint owner?

Violation if Make ATM Unavailable for Week?

04/14/2019

If we deactivate the card reader access to ATM area and make ATM unavailable for about a week, will it cause any violation on to regulation? Our bank’s ATM is inside a building. Anyone who wants to access the ATM machine needs to get in the first door with access via a card. There is another door before you get to the bank’s lobby. There is a small area between the first door and second door. Recently we found a homeless person who gets in that area around midnight and sleeps there. Even worse thing is he urinates during the night and leaves unpleasant smell before leaving early in the morning. We are hoping the person will find a new place to stay if we temporarily shut it down.

State Requirements: Lender-Placed Insurance

04/07/2019

I'm looking for a resource that can provide the state-specific requirements for lender-placed insurance notifications - this would be above/beyond the CFPB model forms.

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