Agree with Randy if the person registers their account directly with PopMoney. However, some internet banking service providers integrate PopMoney directly into the internet banking platform so if I use my bank provided access device to initiate the transfers. In these circumstances, PopMoney should be included in the description of the types of available transfers along with any dollar limitations that you impose. If my internet banking credentials are hacked and fraudulent transfers sent, the bank must investigate, provide provisional credit, etc.
Here in the Midwest I had a number of clients who had the FDIC starting an exam by levying level 2 findings into the exam report as soon as they saw PopMoney because the default disclosures that PopMoney directed the consumer to call PopMoney directly and the FDIC found that PopMoney was not resolving claims timely or providing provisional credit timely. Additionally the default PopMoney disclosures stated that a consumer had 60 days from the date of the transaction to report an error instead of 60 days from the delivery of the statement.
This last came up over a year ago so hopefully vendors have corrected their language, but if your institution if offering PopMoney, it is certainly worth reviewing before your next exam.
Edited by BrianC (09/13/17 03:45 PM)
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