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#2246829 - 12/22/20 04:56 PM Reg E Dispute On A2A Transactions
Joy VH Offline
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Joined: Sep 2017
Posts: 11
Good morning!

I need help. I am getting varying answers on how to handle this so I thought I would come to the experts.

Scenario 1:
A customer logged into her online banking at our bank.
She initiated an A2A transaction.
The transaction was to debit her account at a different bank and credit her account at our bank.
The debit posted to the account at the other bank.
The credit was stopped because her name was not on the debiting account. However that 'other' person is joint on our account.

Where should the Reg E be filed?
At my institution because it was initiated via our online banking?
Or at the other institution because the account was debited but the 3rd party was not credited?

Scenario 2
A customer logged into her online banking at our bank.
He initiated an A2A transaction.
The transaction was to debit her account at a different bank and credit his account at our bank.
The debit posted to the account at the other bank.
The credit was stopped due to suspected fraud. Turns our the transaction was valid.

Where should the Reg E be filed?
At my institution because it was initiated via our online banking?
Or at the other institution because the account was debited but the 3rd party was not credited?
Last edited by Joy VH; 12/22/20 04:57 PM.
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#2246834 - 12/22/20 05:30 PM Re: Reg E Dispute On A2A Transactions Joy VH
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
You are allowing customers to debit accounts at other banks without some sort of pre-verification process that they even have control of those accounts?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2246835 - 12/22/20 05:41 PM Re: Reg E Dispute On A2A Transactions Joy VH
Joy VH Offline
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Joined: Sep 2017
Posts: 11
There is a verification process with our 3rd party vendor but there seems to be an issue with lag time or processing the funds back to the account that should not have been debited.

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#2246839 - 12/22/20 07:52 PM Re: Reg E Dispute On A2A Transactions Joy VH
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
OK - you say the credits were stopped - where did they go? Were they not returned to the other bank for credit to the debited account? You could send them to the other bank - but I am not sure how they can help them. In scenario #1 - how can she order a debit to an account to which she is not party too? Sounds like you have some serious problems with this set up.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2246840 - 12/22/20 08:02 PM Re: Reg E Dispute On A2A Transactions Joy VH
Joy VH Offline
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Joined: Sep 2017
Posts: 11
Our 3rd party vendor has the credits. They want the other bank (who shall remain nameless) to return the transactions as an R06 however; they are not cooperating. They will return the credits to us after 30 days. I agree there are some issues however; those are out of my hands. I am strictly working on the Reg E side of these situations.

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#2246842 - 12/22/20 08:28 PM Re: Reg E Dispute On A2A Transactions Joy VH
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
Not sure how a vendor gets to keep anyone's money? Plus - you were the ODFI on the debit - why would the other bank initiate a R06 return?
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#2246848 - 12/22/20 09:46 PM Re: Reg E Dispute On A2A Transactions Joy VH
rainman Offline
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rainman
Joined: Nov 2004
Posts: 3,068
A claim that there was an unauthorized debit to the account at the other institution would be directed to that institution. A claim by your depositor that a credit should have been received and applied by your institution would be directed to your institution.
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