I am no kind of VISA expert, that is for sure. I just attended a Wolters Klewer quarterly update webinar where they said that our Reg E disclosures needed to be updated for the new Visa Zero Liabilty rules. I relayed this to our Deposit Services manager and she said this does not affect the consumer, they always had zero liability under Reg E and this just meant the bank would not take the loss. Can anyone help me with the disconnect here?

We just updated our deposit account agreement on that avenue. I recommend you read the VISA communication on this change and speak with your VISA representative. It does affect the customer.

This is simply not true. Reg E 1005.6 allows you to hold cardholders liable for at least $50.00 for unauthorized charges due to a lost/stolen access device and possibly more if the cardholder did not notify you within two business days of learning of the loss or theft of the access device.

Prior to October 17, 2014 VISA's Zero Liability superseded Reg E for signature based purchases and PIN based purchases processed on the VISA network. All ATM withdrawals were excluded. This meant that if I lost my VISA card and there were unauthorized ATM withdrawals, you could ignore Zero Liability and follow 1005.6.

VISA has updated its Zero Liability policy to include ATM withdrawals on the PLUS network so if your current disclosures include the language excluding ATM withdrawals from Zero Liability, they should be updated to reflect the current language.

However, because the Visa change is all in favor of the customer, there is no Regulation E requirement that you notify current cardholders of the change.

This is different from the MasterCard change which also expanded the MC Zero Liability coverage, but imposed new conditions on the consumer to obtain that coverage (prompt notice).

Thank you everyone. Our current disclosure does exempt ATM transactions, so we are now all in agreement that the disclosure needs to be updated. Appreciate the reinforcement!