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#1092486 - 12/05/08 03:45 PM Reg E tolerance
liventhedream Offline
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Joined: Mar 2006
Posts: 176
Is there a tolerance with Reg E when it comes to the interest you must give back to the customer to make them whole?

In order to make my customer whole I would owe them 1 penny.

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#1092493 - 12/05/08 03:49 PM Re: Reg E tolerance liventhedream
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,960
Galveston, TX
If you owe them 1 penny - you owe them 1 penny. There are no regulatory tolerences.
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#1092530 - 12/05/08 04:09 PM Re: Reg E tolerance rlcarey
liventhedream Offline
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Joined: Mar 2006
Posts: 176
Would I calculate the interest owed to the customer based on each transaction that day or the total of all transactions for the day?

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#1092541 - 12/05/08 04:14 PM Re: Reg E tolerance liventhedream
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,960
Galveston, TX
If the total of unauthorized transactions was $1,000 and that amount was out of the account for 10 days, then it would be $1,000 x interest rate/365 x 10.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1093243 - 12/08/08 02:50 PM Re: Reg E tolerance rlcarey
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
Essentially, the regulation requires you to make the customer whole. That means that you reconstruct the account history without the unauthorized transaction or after adjusting for an error. If the customer would have earned more interest, you must pay it. If the customer would have avoided a fee (any fee) imposed by your bank, you must refund it.
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John S. Burnett
BankersOnline.com
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