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#2059731 - 01/21/16 03:47 PM Unauthorized debit caused transfer from loc
reknab Offline
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Joined: Oct 2008
Posts: 281
not where I want to be
Customer reported an unauthorized debit card transaction. The transaction caused money to be pulled from his line of credit as his checking did not have enough funds. Are we required to reimburse the interest on the money that was transferred out of the loc?

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eBanking / Technology
#2059749 - 01/21/16 04:30 PM Re: Unauthorized debit caused transfer from loc reknab
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If the customer is a consumer, yes. Regulation E requires that you credit back any fees and adjust any interest to make the consumer whole; i.e., as if the unauthorized transaction didn't happen.
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#2060067 - 01/22/16 07:35 PM Re: Unauthorized debit caused transfer from loc reknab
David Dickinson Offline
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David Dickinson
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Central City, NE
I always say: "Make it like it didn't happen."
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http://www.bankerscompliance.com

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#2060232 - 01/25/16 02:26 PM Re: Unauthorized debit caused transfer from loc reknab
Andy_Z Offline
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Andy_Z
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Ditto the above. My test is, if this was your account or your mom's, what do you think should happen?
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My opinions are not necessarily my employers.
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#2060549 - 01/26/16 05:01 PM Re: Unauthorized debit caused transfer from loc reknab
Naise Offline
Member
Joined: Feb 2014
Posts: 91
I just wanted to say thank you for asking this... it never crossed anyone's mind to do a check for dynamic transfers during the dispute process. I'm having our card department update all procedures right now to include checking interest for HELOCs, credit cards, and below balance fees charged on linked savings and money market accounts.

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#2060874 - 01/27/16 09:39 PM Re: Unauthorized debit caused transfer from loc reknab
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Your responsibility ends at your doors, however, If a domino effect caused the customer to incur fees elsewhere, you aren't required to reimburse him for those costs:
  • Fees for overdrafts or returned deposited checks at other institutions
  • Merchant bounced-check fees
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2061012 - 01/28/16 06:37 PM Re: Unauthorized debit caused transfer from loc reknab
reknab Offline
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Joined: Oct 2008
Posts: 281
not where I want to be
Thanks everyone!!

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