As it relates to your overall rules and agreement, it all requires disclosure, especially liability. They need to be commingled or clearly refer to one another. I see this as an issue of disclosing your contractual agreement with the consumer. Let's look at 1005.7(b)(1) which describes, in part, the initial disclosures you must make under Reg E. "A summary of the consumer's liability, under Sec. 1005.6 or under state or other applicable law or agreement, for unauthorized electronic fund transfers". "other applicable law or agreement" would apply as they are not law, but an agreement you have between the bank, Visa and the consumer.
Last edited by Andy_Z; 09/27/19 09:19 PM.
And the .6 reference is to 1005.6(b)(6) which states "If state law or an agreement between the consumer and the financial institution imposes less liability than is provided by this section, the consumer's liability shall not exceed the amount imposed under the state law or agreement." So again we have "agreement" restrictions that should be disclosed.
These are not "Visa rules" but your obligation to your consumers and whether they be transaction limitations or liability, if they are required by Reg E they need to be specified and differentiated when only applicable to certain transactions such as thru a Visa system.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell