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#1020593 - 08/14/08 08:08 PM Pinless Debits - Visa Disclosures
Jerseygirl Offline
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Jersey Shore
Does anyone know if VISA issued any suggested wording to be used to communicate this to cardholders. Are you disclosing it by updating your Reg. E disclosures. Do I need to send the disclosure to all customers w/ a debit card.
Is it correct that Visa is requiring annual communications with cardholders to alert them that a PIN may not be required to authenticate such transactions?

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#1025114 - 08/21/08 04:25 PM Re: Pinless Debits - Visa Disclosures [Re: Jerseygirl]
ItNeverEnds CRCM Offline
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Looking for my sanity
Jerseygirl - I am wondering the same thing. I just found out about this yesterday and I'm trying to figure out what to do. The thought that we have to annually inform cardholders seems crazy to me. Plus, I don't even think my customers would understand this anyway. Anyone else have any thoughts on this?
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#1025177 - 08/21/08 04:52 PM Re: Pinless Debits - Visa Disclosures [Re: Jerseygirl]
isaidno Offline
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I was just asked to see if BOL had any info. on this. I'll be interested in reading what others have to say.

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#1025660 - 08/21/08 09:45 PM Re: Pinless Debits - Visa Disclosures [Re: isaidno]
Andy_Z Offline
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This is news to me. So will PINless debits apply to zero liability? Is this a convenience item and is there no PIN, no signature, no authentication at all?
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#1026134 - 08/22/08 03:32 PM Re: Pinless Debits - Visa Disclosures [Re: Andy_Z]
Compliancer Offline
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Transactions under certain dollar limits that occur at certified terminals do not require a PIN. An example would be when you buy movie tickets at a self-dispensing machine or use the card at McDonalds to buy lunch.

As for required disclosure of these types of transactions - I know the recent court ruling against Visa regarding Interchange rates for using PINs is the impetus. But I am not familiar with the exact requirements since I am no longer in that area.
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#1026212 - 08/22/08 04:05 PM Re: Pinless Debits - Visa Disclosures [Re: isaidno]
isaidno Offline
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I sent an inquiry about this to another Compliance Helpdesk and they said it was a Visa issue and they would not need to address it. I responded that I believe they are wrong as it appears it would be covered under Reg. E, change notification, initial disclosures and an annual disclosure. I already have information from Visa, but its nothing in detail about what needs to be disclosed.

I'm thinking we'll see more on this soon.

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#1026241 - 08/22/08 04:26 PM Re: Pinless Debits - Visa Disclosures [Re: isaidno]
ItNeverEnds CRCM Offline
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Looking for my sanity
Basically, it's not the no sig required floor limit transactions that some merchant types are allowed to process, it's actually a PIN transaction without the PIN, they've been allowed for certain merchants for bill payments (PG&E and ATT&T have been doing this for awhile). But they were still processed with all Visa protections even though they weren't signature based. But now they aren't going to necessarily go though the Visa network, they'll be processed as any other PIN based transaction (even without the PIN) for all merchants if they participate though whatever PIN network (Accell/Exchange, Star, etc). So Visa is stating that because these transactions will no longer be protected under Visa protections, we have to notify all cardholders initially and annually. I'm just having a hard time with this notification process and can't imagine having to send the disclosure now and then every year. Customers aren't even going to understand it.
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#1027448 - 08/25/08 07:08 PM Re: Pinless Debits - Visa Disclosures [Re: ItNeverEnds CRCM]
C_Groat Offline
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Salt Lake City, UT
At least for Star, if a pin-less transction is performed through the Star network you have full chargeback rights as the merchants are required to accept full responsibility for these transactions. I would assume the other networks have similar provisions to allow these types of transactions to be processed. We do a few chargebacks a day, particularly the bill pays.

I would think it would need to be the merchant that has to disclose their transaction will not be processed through Visa, but a PIN network that may have less protection.

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#1028636 - 08/26/08 08:28 PM Re: Pinless Debits - Visa Disclosures [Re: C_Groat]
Jerseygirl Offline
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Per VISA - issuers are responsible to disclose. I believe that we have until January 1 to provide the disclosure to existing customers.

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#1028743 - 08/26/08 11:39 PM Re: Pinless Debits - Visa Disclosures [Re: Jerseygirl]
Andy_Z Offline
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So these PIN-less transactions, not through the Visa network, will have zero liability or Reg E liability?
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#1030567 - 08/28/08 10:24 PM Re: Pinless Debits - Visa Disclosures [Re: Andy_Z]
C_Groat Offline
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Salt Lake City, UT
Reg E liability as the transactions will not be going through the Visa system and do not qualify for Visa Zero liability, which is what we will need to disclose.

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#1033659 - 09/03/08 05:08 PM Re: Pinless Debits - Visa Disclosures [Re: C_Groat]
Compliancer Offline
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San Francisco, CA
From the Visa Zero Liability Policy for consumer cards (bold added)
http://usa.visa.com/personal/security/visa_security_program/zero_liability.html

Covers U.S.-issued cards only. Does not apply to ATM transactions, PIN transactions not processed by Visa, or certain commercial card transactions. Individual provisional credit amounts are provided on a provisional basis and may be withheld, delayed, limited, or rescinded by your issuer based on factors such as gross negligence or fraud, delay in reporting unauthorized use, investigation and verification of claim and account standing and history. You must notify your financial institution immediately of any unauthorized use. Transaction at issue must be posted to your account before provisional credit may be issued. For specific restrictions, limitations and other details, please consult your issuer.
Last edited by David Grodsky; 09/03/08 05:09 PM.
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#1069577 - 10/23/08 07:05 PM Re: Pinless Debits - Visa Disclosures [Re: Andy_Z]
CalifDreamin Offline
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Far from Calif
Here is an outline of Visa's Final Rule from the Visa website. We, too, are looking for sample language. Since we already have the disclosures in place and just need to add language, we really don't want to have to purchase a new disclosure product from a vendor. This final rule tells you what to include but not how to say it (i.e. you have to give examples to the customer but VISA does not provide those examples).
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#1069580 - 10/23/08 07:07 PM Re: Pinless Debits - Visa Disclosures [Re: CalifDreamin]
CalifDreamin Offline
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Far from Calif
Here's an article on this from the Compliance Headquarters Website: Visa issues Non-Visa Transaction Rules.
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#1072194 - 10/28/08 07:53 PM Re: Pinless Debits - Visa Disclosures [Re: CalifDreamin]
Lil'Belle Offline
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Here is some information I just recieved by fax from our processor: (Our processor said they will not enable PINless non-Visa transactions. However, since we are also members of other networks, our cards have the capability. Our customers with Visa-branded debit cards can use their cards to make bill payments to companies patricipating in these programs with these other networks.)

Issure Requirements
"Visa requires your financial institution to take the following actions to comply with the new rules:

1. Communicate to cardholders that you have enabled non-Visa debit transactions and do not require all such transactions to be authenticated by a PIN. This must be communicated at the time of enablement and at least annually thereafter.

2. Provide cardholders with a list of the debit networks for which such transactions are enabled.

3. Give cardholders examples of the types of actions they must be required to take to initiate a Visa transaction on such cards.

4. Tell cardholders that the provisions of the financial instituiton's cardholder agreement relating to Visa transactions are not applicable for the non-Visa debit transactions. This must be disclosed at the time of enablement and at least annually thereafter."
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#1072461 - 10/29/08 01:19 PM Re: Pinless Debits - Visa Disclosures [Re: Lil'Belle]
Lil'Belle Offline
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I forgot to mention that there is a #5.

5. "Notify Visa of implementation no later than January 1, 2009. To receive a copy of Visa's registration form, contact your account executive."
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#1072583 - 10/29/08 02:59 PM Re: Pinless Debits - Visa Disclosures [Re: Lil'Belle]
ItNeverEnds CRCM Offline
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Looking for my sanity
I'm still wondering how others are handling the notification. Statement stuffers? Separate mailing? Has anyone decided how they're going to do the initial notification and the annual thereafter?
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#1073347 - 10/30/08 01:45 PM Re: Pinless Debits - Visa Disclosures [Re: ItNeverEnds CRCM]
Tesla Offline
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Bumping this because even after reading this thread I am still not sure if Reg E disclosures need to be amended. Anyone?

Also- there is no way a regular consumer is going to understand what the VISA disclosure means. I don't even understand it! What I do get is before a customer had zero liability with a VISA debit card and now if they don't sign for it, they don't. I think that is an increase of liability to the consumer that would trigger a Reg E notice - right????
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#1073408 - 10/30/08 02:34 PM Re: Pinless Debits - Visa Disclosures [Re: Tesla]
Skittles Online
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But can it increase a customer's liability beyond Reg E? I don't think so.
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#1073435 - 10/30/08 02:52 PM Re: Pinless Debits - Visa Disclosures [Re: Skittles]
Tesla Offline
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Maybe I am thinking this through too much. Right now we have amended our debit card application and purchased an annual notice (which is the document I don't think any normal person will understand), if that is all we need to do -that would be great!!

So just so I am sure I am following the pack - no one is amending their Reg E disclosure because the Reg E liability has not increased, correct?
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#1073646 - 10/30/08 04:54 PM Re: Pinless Debits - Visa Disclosures [Re: Tesla]
Anonymous
Unregistered

Does any of this apply to MasterCard branded debit cards?

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#1073775 - 10/30/08 05:53 PM Re: Pinless Debits - Visa Disclosures [Re: ]
Andy_Z Offline
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This is all Visa. I am not aware of similar or other MC change requirements.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1073784 - 10/30/08 06:04 PM Re: Pinless Debits - Visa Disclosures [Re: Andy_Z]
banjo Offline
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Posts: 285
Visa states their Zero Liability Rules do not apply to ATM transactions, PIN transactions not processed by Visa, or certain commercial card transactions. What exactly does "PIN transactions not processed by Visa" mean? Are any PIN based transactions processed by Visa?

I always thought signature based Visa debit card transactions received Visa protections, but PIN based did not. Are there exceptions to this?

Thank you.

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#1073998 - 10/30/08 08:42 PM Re: Pinless Debits - Visa Disclosures [Re: banjo]
C_Groat Offline
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Joined: Mar 2006
Posts: 70
Salt Lake City, UT
Visa operates their own PIN Network - Interlink for PIN Debit transactions and Visa/Plus for ATM transactions. If the PIN transaction is flowed through Interlink, the PIN Debit transaction is protected under Visa's Zero Liability. If the transaction is processed through Star, NYCE, Pulse or any of the other Debit Networks it is not covered.

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#1074050 - 10/30/08 09:27 PM Re: Pinless Debits - Visa Disclosures [Re: C_Groat]
banjo Offline
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Well, that is what I was starting to think, but I received the following in an email from Visa's Account Support Center today (we use the Interlink Network):

"PIN based transactions would be going through the Interlink Network, not Visa's. Therefore, may not receive the Visa-associated protections and benefits such as Zero Liability and dispute resolution. Signature based transactions would be protected under Visa's consumer protections and benefits."

Now I'm really confused. In searching Visa's website and cannot find anything that clears this up.

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#1075851 - 11/04/08 02:58 PM Re: Pinless Debits - Visa Disclosures [Re: banjo]
banjo Offline
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I located the name of our Visa representative and forwarded my question to her. Here is what she said:

Interlink is covered by Zero Liability. There are non-Visa debit PIN transactions that are not processed via Visa's network and they are not covered by zero liability (ex. Star).

This confirms what C_Groat stated. Apparently, the employee at Visa's Support Center did not fully understand their policy.

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#1077174 - 11/05/08 08:45 PM Re: Pinless Debits - Visa Disclosures [Re: banjo]
banker-12 Offline
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Posts: 1,146
Since this is a Visa requirement and not Reg E, are we really required to send out this disclosure and modify our existing reg E dislosure. If we decide not to do it, will examiners be looking for this.

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#1077208 - 11/05/08 09:01 PM Re: Pinless Debits - Visa Disclosures [Re: banker-12]
John Burnett Offline
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Cape Cod
Interesting, is it not, that two different Visa reps appear to view Interlink differently, Banjo. Which one do you believe?
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#1077714 - 11/06/08 03:43 PM Re: Pinless Debits - Visa Disclosures [Re: John Burnett]
banjo Offline
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Posts: 285
This last one. She sent me information backing up what she told me. She also asked for the email I received from Visa's esupport and a couple of days ago I received an email correction from esupport stating Interlink transactions were indeed covered by Zero Liability.

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#1078094 - 11/06/08 08:50 PM Re: Pinless Debits - Visa Disclosures [Re: CalifDreamin]
Lil'Belle Offline
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Texas, United States
Here is sample language from Pulse:

Your Visa debit card also allows you to conduct transactions on the PULSE® [and _______][insert names of other PIN debit networks, if applicable] debit network[s], which will generally require you to enter your PIN. Some merchants are authorized to accept non-Visa debit transactions without requiring you to enter your PIN. If you choose to sign to authorize a debit transaction, the transaction will be routed as a Visa transaction. Provisions of your cardholder agreement that specifically relate to Visa transactions are inapplicable to non-Visa debit transactions.


PULSE believes this sample notice is sufficient to satisfy the requirements of Visa Operating Regulation 6.2.A.7.b, but you may wish to consult with your advisors to determine whether modifications should be made to reflect your financial institution’s particular circumstances.

Hope this helps some.
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#1080623 - 11/12/08 07:25 PM Re: Pinless Debits - Visa Disclosures [Re: Lil'Belle]
Jerseygirl Offline
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Posts: 684
Jersey Shore
So have we decided if this is a reg E issue or a VISA issue? Do I need to comply for Regulatory reasons or is it to be in compliance with my VISA contract?

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#1080656 - 11/12/08 07:58 PM Re: Pinless Debits - Visa Disclosures [Re: Jerseygirl]
Skittles Online
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TN
It's not a Reg E Issue - Reg E hasn't changed.
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#1080845 - 11/12/08 10:06 PM Re: Pinless Debits - Visa Disclosures [Re: banjo]
banker-12 Offline
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Posts: 1,146
Does the Cirrus network enable non-visa debit transactions without a pin?

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#1081168 - 11/13/08 04:07 PM Re: Pinless Debits - Visa Disclosures [Re: banker-12]
Andy_Z Offline
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I agree with Duchess. This isn't a new transaction the consumer can make and isn't a Reg E issue.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1081290 - 11/13/08 05:48 PM Re: Pinless Debits - Visa Disclosures [Re: Andy_Z]
CalifDreamin Offline
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Far from Calif
So, it's not a Reg. E issue, but where are you disclosing this if not in your Reg. E disclosure?
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#1082514 - 11/15/08 12:06 AM Re: Pinless Debits - Visa Disclosures [Re: CalifDreamin]
compliancegeek Offline
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Midwest
We are providing the Visa-required notice in a statement letter/message. We are also amending our Reg E disclosure with not only the VISA required disclosure, but to say that any debit transaction not processed on a VISA network does not have the protection of Visa's zero liability. We needed to use the Reg E disclosure to inform new debit card customers of the Visa information, since they won't have benefit of our December statement message. I wrote my own disclosure and would be happy to share.

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#1083310 - 11/18/08 03:38 PM Re: Pinless Debits - Visa Disclosures [Re: compliancegeek]
mcb80 Offline
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Posts: 7
New Jersey
We are in the process of updating our Reg. E disclosure and also, debating what type of seperate disclosure (i.e. statement message, buck slip, etc.) we should send to our customers. I would like to see what you came up with for your disclosures, especially the "examples of the types of actions a cardholder may be required to make to initiate a Visa transaction". Any help would be greatly appreciated.

Thanks

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#1083365 - 11/18/08 04:40 PM Re: Pinless Debits - Visa Disclosures [Re: mcb80]
compliancegeek Offline
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Posts: 129
Midwest
mcb80 - Just pm me with your email address and I'll send you my Word doc.

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#1083576 - 11/18/08 07:23 PM Re: Pinless Debits - Visa Disclosures [Re: compliancegeek]
complygirl Offline
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Joined: Oct 2004
Posts: 822
midwest
I know we have to notify card holders of this new VISA rule. Several posted have also mentioned updating the Bank's Reg. E disclosure.

Our Reg. E disclosure currently has a small section on VISA liability, within that section it states: "Additional Limit on Liability for VISA card. Unless you have been grossly negligent or have engaged in fraud, you will not be liable for any unauthorized transactions using your lost or stolen VISA card. This additional limit on liability does not apply to ATM transactions, or to transactions using your Personal Identification Number which are not processed by VISA."

Does this verbiage cover the new non-VISA debit transaction rule (since it mentions transactions using your PIN not processed by VISA)? I'm just wondering if this will suffice, or if additional verbiage is needed. Thanks.

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#1083623 - 11/18/08 08:09 PM Re: Pinless Debits - Visa Disclosures [Re: complygirl]
compliancegeek Offline
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Midwest
I had a conversation with our Visa rep last week, and she indicated that any debit transaction with, or without a PIN, that is conducted on a NON-VISA network, would not be covered by zero liability. Our Reg E disclosure says essentially what yours does, and so we viewed that as increased liability to the customer - based on what we disclosed. We revised our Reg E to say "Unless you have been grossly negligent or have engaged in fraud, you will not be liable for any unauthorized transactions conducted through a Visa network." In a nutshell, transactions conducted through a Visa network = zero liability for unauthorized. Transactions conducted through a non-Visa network = Reg E limits of liability for unauthorized - regardless of PIN. That's my take on it.

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#1083643 - 11/18/08 08:36 PM Re: Pinless Debits - Visa Disclosures [Re: compliancegeek]
complygirl Offline
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Posts: 822
midwest
Thanks compliancegeek.

Are you providing your disclosure about the new rule to all cardholders? We issue both ATM only cards and VISA debit cards...would our ATM only cardholders also need to be notified of this new rule? Thanks.

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#1083792 - 11/18/08 11:40 PM Re: Pinless Debits - Visa Disclosures [Re: complygirl]
compliancegeek Offline
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Midwest
We are sending the disclosure to everyone with an account having the capability to send/receive an EFT - just because their Reg E disclosure has been revised - whether or not the card they hold is capable of a debit transaction. It was just easier that way.

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#1083919 - 11/19/08 01:23 PM Re: Pinless Debits - Visa Disclosures [Re: complygirl]
John Burnett Offline
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Cape Cod
Originally Posted By: complygirl
Thanks compliancegeek.

Are you providing your disclosure about the new rule to all cardholders? We issue both ATM only cards and VISA debit cards...would our ATM only cardholders also need to be notified of this new rule? Thanks.


That depends on what "ATM Only" really means. Can those cards be used in an ATM network POS transaction? For example, a lot of merchants accept NYCE or similar cards for PIN POS purchacases (as noted, some may accept PIN-less card transactions on those networks. If your ATM customer can access a transaction account with that "ATM only" card, there's a real possibility the card will work at a gas pump or grocery store.
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#1084732 - 11/20/08 04:24 AM Re: Pinless Debits - Visa Disclosures [Re: John Burnett]
rahrah_c Offline
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Joined: May 2008
Posts: 11
Grand Forks, ND
Has anyone come up with examples of scenarios to provide to customers? Is there any way a customer could opt-out from having their transaction post on the non-visa networks?

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#1084734 - 11/20/08 04:53 AM Re: Pinless Debits - Visa Disclosures [Re: rahrah_c]
rahrah_c Offline
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Joined: May 2008
Posts: 11
Grand Forks, ND
If I'm understanding this correctly it sounds like even though our cards have the Visa logo which typically means 'visa's zero liability' (from our customer's eyes) that this may not be the case since the actual transaction could be processed on a different network.

How would we explain that in simple terms to make sense to customers?

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#1084907 - 11/20/08 03:32 PM Re: Pinless Debits - Visa Disclosures [Re: compliancegeek]
Freedom Bank - Offline
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Joined: Aug 2006
Posts: 1
Would you send me your Visa non-pin disclosure.

I certainly appreciate it.

Freedom

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#1085474 - 11/20/08 10:30 PM Re: Pinless Debits - Visa Disclosures [Re: Freedom Bank - ]
Mississippi Offline
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Joined: Oct 2006
Posts: 12
I am also looking for a sample disclosure and sample wording for Reg E. Please e-mail to sodomREMOVETHIS@firststatebnk.com.


Andy's notes: Because web crawlers look for email addresses to add to spam lists, it is generally better to have PMs sent to you than to post your email address. AT the very least, make the address such that it needs a person to alter it so it is usable.
Last edited by Andy Z; 11/21/08 03:35 PM.
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#1085665 - 11/21/08 02:19 PM Re: Pinless Debits - Visa Disclosures [Re: Mississippi]
banjo Offline
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Posts: 285
Wolters Kluwer (formerly Bankers Systems) has slip sheets for notifying customers available.

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#1088423 - 11/26/08 04:16 PM Re: Pinless Debits - Visa Disclosures [Re: compliancegeek]
CatNip Offline
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Joined: Sep 2008
Posts: 16
Could you share your disclsoure with me. Thanks

CatNip

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#1088428 - 11/26/08 04:18 PM Re: Pinless Debits - Visa Disclosures [Re: compliancegeek]
CatNip Offline
New Poster
Joined: Sep 2008
Posts: 16
deleted
Last edited by CatNip; 11/26/08 09:05 PM.
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#1096080 - 12/11/08 10:08 PM Re: Pinless Debits - Visa Disclosures [Re: Jerseygirl]
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,466
Midwest
Our current Reg E disclosure states: Unless you have been grossly negligent or have engaged in fraud, you will not be liable for any unauthorized transactions using your lost or stolen VISA check card. This additional limit on liability does not apply to ATM transactions using your PIN which are not processessed by VISA.

We had our brochures printed in 7/2008 and all clients received the updated brochure. Would we need to provide any additonal disclouses?

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#1096869 - 12/12/08 10:34 PM Re: Pinless Debits - Visa Disclosures [Re: ahkcompliance]
John Burnett Offline
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Joined: Oct 2000
Posts: 38,722
Cape Cod
Check out the Zero program. I think it also excludes PINned POS transactions, since they don't go the Visa route, either.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1100423 - 12/19/08 05:50 PM Re: Pinless Debits - Visa Disclosures [Re: John Burnett]
Marathon Junkie Offline
Member
Joined: Mar 2001
Posts: 50
Does the disclosure need to be mailed to all cardholders prior to Jan 1?
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#1632700 - 11/28/11 07:19 PM Re: Pinless Debits - Visa Disclosures [Re: banjo]
cheech Offline
100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
Is this an annual mailing or one time thing?

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#1632830 - 11/29/11 12:10 AM Re: Pinless Debits - Visa Disclosures [Re: cheech]
'Lil Freak! Offline
10K Club
'Lil Freak!
Joined: Sep 2005
Posts: 10,595
The psych ward
From the VISA U.S.A. Operating Regulations:

6.2.A.7.b An Issuer that enables Non-Visa Debit Transaction processing on or after July 1, 2008, and does not require that all such transactions be authenticated by a PIN must:

Clearly communicate to its Cardholders at the time of implementation of such processing or at the time of issuance, and on an annual or more frequent basis thereafter, that it has enabled Non-Visa Debit Transaction processing and that it does not require that all such transactions be authenticated by a PIN
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