Thread Options
#1540622 - 04/26/11 01:24 PM Cancelling Debit Card
MadisonCali Offline
Power Poster
Joined: Jun 2006
Posts: 2,515
So, I would imagine there's been some discussion and/or guidance on this, but I can't find it.

We make OD decisions 'ad hoc' at our bank. We do not offer to let customers 'opt in' to pay overdrafts.

The President wants to cancel the cards of a couple of customers who have been abusing their POS privileges by playing the system (pay at the pump overdrawing them, etc). Can we do this and call it 'account abuse'?

Thanks.
_________________________
The beatings will continue until morale improves...

Return to Top
Deposits and Payments
#1540878 - 04/26/11 04:42 PM Re: Cancelling Debit Card MadisonCali
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
There are no regulations that govern the cancellation of debit cards since it is not a credit product. In fact, a lot of banks will not re-issue debit cards if there have been too many questionable Reg. E claims.

You do not even need to call it "account abuse", you can just inform the customer that the bank is cancelling their card because the customer has not handled the use of the card in a satisfactory manner.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1540898 - 04/26/11 04:58 PM Re: Cancelling Debit Card Princess Romeo
MadisonCali Offline
Power Poster
Joined: Jun 2006
Posts: 2,515
Thanks for the confirmation smile
_________________________
The beatings will continue until morale improves...

Return to Top
#1541044 - 04/26/11 06:23 PM Re: Cancelling Debit Card MadisonCali
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
You probably should have a written procedure for this - IMO your regulators will take a dim view if do this to some customers but not all - I think consistency will be a key factor.

Seems like I heard this addressed somewhere, but cannot find my materials - I'll keep looking.
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

Return to Top
#1542178 - 04/27/11 08:31 PM Re: Cancelling Debit Card RBanker
MadisonCali Offline
Power Poster
Joined: Jun 2006
Posts: 2,515
Good idea...we've done it very sporadically in the past, but I wasn't sure if the new debit card OD rules should be impacting our decision-making process at all...
_________________________
The beatings will continue until morale improves...

Return to Top
#1542478 - 04/28/11 02:39 PM Re: Cancelling Debit Card MadisonCali
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,557
Cape Cod
Just don't mention in your procedures that the action is taken because you haven't received an opt-in to OD fees for card transactions. You apparently haven't offered the opportunity and don't intend to, but you also don't want to be cited for taking action based on no opt-in.

Make it all about account or card mismanagement.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1542990 - 04/28/11 07:38 PM Re: Cancelling Debit Card John Burnett
Soccer Offline
Diamond Poster
Joined: Jan 2010
Posts: 1,018
Utopia
We also have included on the debit card application the following: "Property of the Issuer; Cancellation Rights:
Each card is the property of Issuer and must be surrendered upon demand. Each card can be canceled by Issuer and the privileges thereof revoked at any time without prior notice"
_________________________
Everything happens for a reason

Return to Top

Moderator:  John Burnett