Thread Options
#2227338 - 12/13/19 03:54 PM Debit Card Conversion/Changes
Bankwoman1 Offline
Platinum Poster
Joined: Dec 2015
Posts: 550
Midwest
We recently went thru a debit card platform conversion. One of the changes that came about because of this conversion are transaction limits on our debit and ATM cards. There are now limits to the number of POS transactions and ATM withdrawals that can be made in a day. While the limits are pretty generous, 20 POS transactions and 6 ATM withdrawals, shouldn't we have disclosed this prior to it going into effect? And do our Reg E disclosures need to be updated to include these limits? There were no limits previously.

Return to Top
eBanking / Technology
#2227339 - 12/13/19 04:07 PM Re: Debit Card Conversion/Changes [Re: Bankwoman1]
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 5,198
Illinois
Yes to both.

1005.8(a)

(a) Change in terms notice. (1) Prior notice required. A financial institution shall mail or deliver a written notice to the consumer, at least 21 days before the effective date, of any change in a term or condition required to be disclosed under ยง 1005.7(b) of this part if the change would result in:
(i) Increased fees for the consumer;
(ii) Increased liability for the consumer;
(iii) Fewer types of available electronic fund transfers; or
(iv) Stricter limitations on the frequency or dollar amount of transfers.

1005.7(b)(4) Content of Disclosures

(4) Types of transfers; limitations. The type of electronic fund transfers that the consumer may make and any limitations on the frequency and dollar amount of transfers. Details of the limitations need not be disclosed if confidentiality is essential to maintain the security of the electronic fund transfer system.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2227340 - 12/13/19 04:09 PM Re: Debit Card Conversion/Changes [Re: Bankwoman1]
Bankwoman1 Offline
Platinum Poster
Joined: Dec 2015
Posts: 550
Midwest
I thought so....

Thanks again for your help Brian! I will see if they can get this disabled until we can get it disclosed.

Return to Top

Moderated by:  Andy_Z