Let me say this first. I am only familiar with Reg E rules, not really Visa Liability rules and ACH rules. Any training I've had seems to just regurgitate the rules, but never gives real life examples of the application of the rules in conjunction with Visa Zero Liability and ACH. So I feel a bit blind.
BrianC, what do you mean that "the Bank is not providing Zero Liability protections since the cardholder did not safeguard their card from loss/theft"? Can we do that for those early transactions? I'm not sure that the customer was negligent since maybe it was a waiter at a restaurant that took a picture of the card and used that information. In my scenario, I was thinking that the negligence came in in that they did not monitor their account statement and report to us any unauthorized transactions within 60 days as we require in our disclosures. Is negligence under Visa tied directly to safeguarding the card only, or is negligence a possibility when not monitoring your account associated with the Visa debit card?
Regarding "accepted access device", besides the physical card, what are some other "real" examples? Electronic Banking login, password, passcode? Telephone banking passcode? Personal identification numbers (PINs) but in what context? Cell phones, but in what context?
Thanks in advance!
Always learning something new...