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#2267939 - 03/20/22 09:39 PM Communicating transaction limits to customers
Crimson Compliance Offline
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Joined: Sep 2021
Posts: 11
Hi all,

My FI's risk management team often encounters situations where customers' transactions are blocked due to internal transaction limits and velocity limits (such as $ ACH per transaction, $ per timeframe, etc.) which are set up for AML and fraud risk management, however, when a customer contacts Customer Support they want to know why the ACH or credit card transaction was declined/blocked. My concern is that if we tell a customer a transaction limit, then this may leave us more vulnerable to fraud and/or money laundering.

My question: How do (or how should) financial institutions communicate transaction limits without compromising risk management?

Regards,
Crimson Compliance

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Risk Management
#2267943 - 03/21/22 01:32 PM Re: Communicating transaction limits to customers Crimson Compliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,269
Galveston, TX
This post seems to be sort of apples and oranges. First you talk about ACH velocity, which I assume you are talking about business customers. Then you throw in credit cards, which I assume are on consumer transactions. Your consumers should already be informed of any transaction limits under Regulation Z for credit cards and Regulation E for electronic transactions.
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#2268254 - 03/28/22 12:28 PM Re: Communicating transaction limits to customers Crimson Compliance
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,482
Pulling people out of the ditc...
imagine you banked somewhere and did not know the limit for daily use on debit card, ATM daily usage, credit card limit or usage amount, debits or credits via ACH, and anything else that may impact your ability to simply transact business...would you bank there long after the 1st or 2nd time this impacted you? i wouldn't.

beside that, doesn't your deposit agreement disclose those limits?
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