If the daughter wants "privacy" over their debit card purchases, they should have an individual account that mom can't access.
1. Reg E specifically allows either party to notify the institution of an electronic funds transfer error. We would be in violation of the regulation if we told mom we couldn't accept a claim from her that was charged to the daughter's card.
2. This is just good customer service. What possible reason would we have to refuse?
3. Yes.
4. Consider this scenario: Mom calls in to request a card be closed because her daughter had her purse stolen with the debit card in it. The bank refuses because they want to hear from the daughter even though the daughter is at the police station filing a report and can't call right now. Several unauthorized charges occur because the bank refused to close the card. Guess who pays? The bank!!!
5. The joint owner should only be given information relating to the account on which they are an owner.
Staff should review the commentary to 1005.6.
2. Notice by third party. Notice to a financial institution by a person acting on the consumer's behalf is considered valid under this section. For example, if a consumer is hospitalized and unable to report the loss or theft of an access device, notice is considered given when someone acting on the consumer's behalf notifies the bank of the loss or theft. A financial institution may require appropriate documentation from the person representing the consumer to establish that the person is acting on the consumer's behalf.
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