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#2248029 - 01/22/21 06:45 PM Cash Advances
Comply Central Offline
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Joined: Aug 2018
Posts: 92
I have a few questions concerning cash advances:

1. Are there any rules to prevent us from charging a customer a cash advance fee and if not, is there a limit on what we can charge?
2. If we can charge the fee, can we waive it if the customer is paying a loan payment?
3. Can we waive it for any reason, like if the customer has a loan or if they have deposits over a certain amount?
4. Do the fees and the criteria for charging fees have to be on any disclosures or posted anywhere?
5. Are there any risks to consider in doing a cash advance for a non-customer?

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#2248031 - 01/22/21 06:53 PM Re: Cash Advances Comply Central
BrianC Offline
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#2248033 - 01/22/21 07:01 PM Re: Cash Advances Comply Central
rlcarey Offline
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Brian - and all this time I thought that was the official thread? smile
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#2248034 - 01/22/21 07:04 PM Re: Cash Advances BrianC
Comply Central Offline
Member
Joined: Aug 2018
Posts: 92
Thank you, Brian. Just to make sure I understand this correctly, no fee can be charged and we must provide services to all cardholders whether customer or non-customer? Are there any risks we should consider for non-customers?

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#2248040 - 01/22/21 07:59 PM Re: Cash Advances Comply Central
Comply Central Offline
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Joined: Aug 2018
Posts: 92
Does this imply that a fee can be charged as long it is not on a pre-paid card?

4.15.3 Discount or Service Charges
In the U.S. Region, the Rule on this subject is replaced with the following:
With respect to the acceptance of prepaid Cards, the Customer and each of its
authorized cash disbursement agents must disburse all cash disbursements at par
without any discount and without any service or other charge to the Cardholder,
except as may be imposed to comply with applicable law. Any charge imposed to
comply with applicable law must be charged to and paid by the Cardholder
separately and must not be included in the total amount of the cash disbursement.
With respect to the acceptance of any type of Mastercard Card other than a
prepaid Card, a Customer or its authorized cash disbursement agent may charge a
fee for performance of the cash disbursement service (herein, a “Manual Cash
Disbursement Access Fee”). Any Manual Cash Disbursement Access Fee charged
must be:
1. Not greater than the fee established for any other payment network.
2. Disclosed to the Cardholder before a Transaction authorization request is
submitted. At the time of disclosure, the Cardholder must be afforded the
opportunity to opt out of completing the Transaction.
3. Disclosed on the Transaction receipt.
4. Detailed in DE 28 (Amount, Transaction Fee) of the Authorization Request/
0100 or Financial Transaction Request/0200 message.
5. Detailed in DE 54 (Amounts, Additional) of the First Presentment/1240
message.
6. Included in the total Transaction amount transmitted in DE 4 (Amount,
Transaction) of authorization and clearing messages.)

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#2248042 - 01/22/21 08:02 PM Re: Cash Advances Comply Central
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
Randy - Since I only independently contract with BOL and don't actually work for BOL, I don't want to overstep my bounds. smile

Lynzey:
No fees can be charged on debit and prepaid cards.

You must provide services to all customers and non-customers.

The issuers bears the risk of fraud losses as long as you follow V/MC identification and authorization procedures when performing a cash advance. This means - Tellers should never "force" a transaction based on a voice authorization where the non-customer hands them a phone number to call or a cell phone as they will end up obtaining a voice authorization from the fraudster. Only call the number on your cash advance terminal if a voice authorization is needed.
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#2248047 - 01/22/21 08:47 PM Re: Cash Advances BrianC
Comply Central Offline
Member
Joined: Aug 2018
Posts: 92
Thank you for your help.

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#2248094 - 01/25/21 04:53 PM Re: Cash Advances BrianC
Comply Central Offline
Member
Joined: Aug 2018
Posts: 92
Would the fee restriction apply on advances from a Mastercard credit card? Sorry for so many questions, but I want to make sure I have all the information correct for an upcoming discussion about this.

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#2248095 - 01/25/21 04:58 PM Re: Cash Advances Comply Central
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
You can charge a fee for cash disbursements on a credit card provided that you follow items 1-6 in the citation you provided above.
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#2248127 - 01/25/21 08:34 PM Re: Cash Advances BrianC
Comply Central Offline
Member
Joined: Aug 2018
Posts: 92
Thank you!

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