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#2248342 - 01/28/21 09:20 PM Reg E-Unauthorized Venmo Transactions
Jenny Roberts Offline
100 Club
Joined: Feb 2014
Posts: 164
Tennessee
We have a customer that thinks their granddaughter got her debit card information and opened a Venmo account and has incurred several charges. Does the bank have to give provisional credit or does the customer need to deal with Venmo or both?

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Operations Compliance
#2248345 - 01/28/21 09:28 PM Re: Reg E-Unauthorized Venmo Transactions Jenny Roberts
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,365
Illinois
Quote
thinks their granddaughter got her debit card information and opened a Venmo account


How does this not do anything but meet the definition of an "unauthorized electronic funds transfer" in 1005.11(a).

Your customer made a claim that met all the conditions of 1005.11(b). Now you must investigate following the requirements of 1005.11(c) which includes provisional credit. You cannot require that the customer try to resolve with the merchant before starting your investigation.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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#2248349 - 01/28/21 09:51 PM Re: Reg E-Unauthorized Venmo Transactions BrianC
Jenny Roberts Offline
100 Club
Joined: Feb 2014
Posts: 164
Tennessee
That was what I stated but am being questioned on it. Thanks!

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#2248350 - 01/28/21 09:54 PM Re: Reg E-Unauthorized Venmo Transactions Jenny Roberts
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,365
Illinois
The fact that a family member is involved is irrelevant to Reg E unless the customer admits to granting authority to the family member to use their access device and that person exceeds the authority. (See 1005.2(m))
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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