I'm familiar with the commentary to 1005.11(c) stating that there cannot be a charge or "chilling" effect to notifying the bank of an error.

Curious what others thoughts are as to replacement cards. If fraud occurs on a consumer's debit card, we require the card to be shut down. But if they want a new card, there is a $10 fee for a replacement. What are your thoughts as to whether or not this is allowed, or is it possibly "chilling"? Are you aware of any issues related to this practice from other banks?

It's up to them if they want another card - well actually it is up to the bank to allow it to happen. I see it as two totally separate issues. However, I am not sure I would penalize them for a new card if they neither lost their original card or did not in anyway contribute the fact that their number had been stolen.

Thanks for your thoughts.

I agree, I don't want to penalize the customer when it wasn't their fault, but that is our current policy. If you have a fraud on your card, you can either choose to operate without a card, or pay $15. So, in reality you might only be getting a net $85 back from your $100 fraud. I can see how someone might see it as a "chilling" effect. Was kind of hoping others might agree this could be seen as a regulatory concern.

I think this is a regulatory concern. Remember the refunds for Regulation E disputes are to make the customer whole. Charging them a replacement card fee takes away from that.

We have a fee for replacement cards, but do not charge it when closing a card for disputes. We only charge it if someone loses their card (with no fraudulent activity) or the card is damaged.

Interesting way to look at it. Thanks for sharing.