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#2254794 - 06/03/21 03:17 PM Business Debit Cards
Anonymous
Unregistered

I’m new to the deposit/operations side, particularly Reg. E for debit cards.

I understand that the protections of Reg. E are for consumer cards only, not entities (businesses), that those protections are disclosed at account opening or when the card is issued and that those protections are separate from any chargeback rights under the VISA rules.

Without the Reg. E rules do business debit cards have any protection from unauthorized transactions? Do they have chargeback rights? Without the initial Reg. E disclosure, how are these rules/procedures disclosed to business debit card holders?

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#2254796 - 06/03/21 03:27 PM Re: Business Debit Cards Anonymous
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
Visa requires that you provide the same chargeback rights to all of its branded cards. However, since Reg E doesn't apply you can condition exercising chargeback rights on the business' behalf on the business jumping through all of Visa's hoops such as providing copies of receipts, merchant contact, etc. that you cannot require as part of a Reg E investigation.

Visa also extends its Zero Liability protections to small business debit cards for fraudulent transactions so your account agreement should reflect these protections.

Since the business is not covered by Reg E, the bank's legal counsel should have been involved in drafting the business debit card agreement to specify what liability the business has for reporting unauthorized transactions, investigation, etc. You don't have to follow the Reg E model language and can put greater responsibility on the business for timely reporting, safeguarding the card, etc.
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#2256150 - 06/30/21 01:10 PM Re: Business Debit Cards BrianC
TeamComply Offline
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Joined: Aug 2016
Posts: 543
And what are the MasterCard rules with regard to business debit cards and unauthorized transactions?

Does MasterCard also required FIs to provide the same chargeback rights to all of its branded cards?

And does MasterCard also extend its zero liability protections to small business debit cards for unauthorized transactions?

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#2256156 - 06/30/21 02:53 PM Re: Business Debit Cards Anonymous
burkemi Offline
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Joined: Nov 2013
Posts: 549
To my understanding, yes to all of the above. Brian is the expert, hopefully he can verify.

But I do want to add - Reg E does not apply to business accounts; however, if you are providing Reg E disclosures to business customers, you are bound by your own disclosures and will have to provide Reg E protections where they don't belong.
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#2256218 - 07/01/21 03:35 PM Re: Business Debit Cards Anonymous
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
Both card brands protect the integrity of their brand by requiring issuers to assist cardholders when chargeback rights are available. Your contractual obligation to V/MC is in addition to your compliance obligations to Reg E.
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