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#1800084 - 04/01/13 06:02 PM Debit card disclosures
Banker57 Offline
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Joined: Jul 2010
Posts: 439
Minnesota
In our new account disclosures we include the ATM/POS/Debit card section. Do we need to have a separate authorization signed by the customer when they first request a card?

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General Discussion
#1800682 - 04/02/13 08:37 PM Re: Debit card disclosures Banker57
'Lil Freak! Offline
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'Lil Freak!
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Posts: 10,596
The psych ward
I'm not sure if I totally follow your questions, but under Reg. E an "application" for an access device may be oral or written; there's no signature requirement.
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#1800698 - 04/02/13 09:03 PM Re: Debit card disclosures Banker57
Doug Hendrickson Offline
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Doug Hendrickson
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First, if your initial account opening disclosure contains the verbiage for an ATM/POS/Debit card (Reg E disclosure), there is no requirement to give them another disclosure when they request the card subsequent to the opening of the account.

Second, I agree that there is no signature requirement for the "application" for an access device. However, we use a canned form from DepositPro that we send to our operations group to enter the card data on the system and order the card. It has a signature line, indicating that the customer has ordered the card and agrees to abide by the Reg E disclosures already provided to them. It may not be necessary, but it's helpful to substantiate that the customer did request the card.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1800713 - 04/02/13 09:21 PM Re: Debit card disclosures Banker57
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,470
Midwest
We usea form similar to Doug. The teller or CSR will fill the form out and have the customer sign it and then it is forwarded onto card services to be ordered and placed on the sytem.

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#1800750 - 04/02/13 11:42 PM Re: Debit card disclosures Banker57
'Lil Freak! Offline
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'Lil Freak!
Joined: Sep 2005
Posts: 10,596
The psych ward
Our EFT disclosures, like Doug's, are in our account agreement and the signature card consents to having received all disclosures. We used to have the member sign a form, but now cards can be ordered and pinned at the FSR desk.
_________________________
No, I didn't lose my mind. It got scared and ran away.

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#1800792 - 04/03/13 01:23 PM Re: Debit card disclosures Banker57
bigfish Offline
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Joined: Oct 2006
Posts: 66
trolling for the big one
We include our Reg. E disclosure in our new account disclosures, but provide the customer an additional separate Reg. E disclosure when a customer subsequently adds an EFT service, such as a debit card or online banking. You may want to review the commentary to 1005.7(a).

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#1800815 - 04/03/13 02:13 PM Re: Debit card disclosures bigfish
Doug Hendrickson Offline
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Doug Hendrickson
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Are you using one of those 'instant issue' debit card devices? If so, from whom and how do you like it?
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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