09/08/2024
We are considering allowing customers to use FedNow to receive instant wires. The concern is our customer receives the wire and spends the funds and a day, two, or more go by and we receive a claim to return the funds due to fraud. Which bank would have liability for a fraudulent wire transfer, the sending bank or the receiving bank? Can you provide the references that I should be looking into (UCC, Regulations, etc.)?
08/25/2024
We have a customer that lost their debit card but didn't notify us until day five. Under Visa's zero liability policy, would this be considered "gross negligence"? The charges do not all add up to $500.00, so are we required to give the customer any credit at all?
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?
12/02/2018
Can I restrict an account up to 60 days for investigation purposes when depository account experiences return items that return as fraudulent or
unauthorized? Also can the 60-day restriction be extended after each returning deposit? When do I start counting the 60 days? When the last return
item is received?
EX: receive 1st return item on 10/1- 60 days is 11/29, receive 2nd return item on 10/3 can I extend the restriction until 12/1, so on and so on?
09/16/2018
A customer has claimed $700+ in ATM withdrawals are unauthorized following her loaning her vehicle, in which she left her purse and debit card, to a "down and out" acquaintance who she admitted may have previously had the opportunity to shoulder-surf her PIN. Seems cut and dry that customer has a bona fide dispute but bank has previously provided final credit of over $700 to same cardholder following unauthorized debits after she took in a homeless teen, put her purse with debit card on the kitchen counter, then left for a few hours to run errands, which suggests that customer is using the bank to reimburse her "philanthropy." Do we have a leg to stand on in saying customer is not taking reasonable care of her cards to the extent that her dispute can be denied?
02/25/2018
If a merchant provides a signed receipt on a disputed debit card charge and we know for sure it is not the customer’s signature that is disputing the charge, is there anything a Bank can do?I know Reg E is very consumer friendly but if the signature definitely does not match, the Bank will have to side with the customer and assume it was fraud and work the dispute, and take any loss associated with it. I am curious if there is anything else the Bank can do from a Regulation stand point that could help the Bank not take a loss.
11/08/2015
A consumer customer had 76 WEB/ACH unauthorized transactions occur between July 8, 2014, and July 27, 2015, totaling $74,143. The bank was able to return the most current 60 day transactions to the originating bank. The transactions were performed by the customer's secretary to pay her personal bills. What is the remaining liability to the bank?
08/18/2014
As an issuer of MC branded Debit cards, are we required to provide the Additional Limits on Liability for MasterCard branded debit cards aka zero liability section. With recent changes at MC, the unauthorized transfer section of the Reg E disclosure will need updating. We would like to notify existing card holders of the change, but remove the paragraph for new customers. We have this query into our MC representative but no response yet.
05/19/2014
We issue MasterCard debit cards. If a customer disputes a transaction where a PIN was used per Reg E and MasterCard, can we assess the $50.00 dollar liability? Card wasn't lost or stolen.