Reg. E will apply when the card is used one way, VISA/MC rules will apply when used another. As an additional twist, Reg. Z may apply.
My customer goes to an ATM and makes a withdrawal, that is E. Then he goes to a store and uses the debit feature, that is MC/VISA. Reg. Z can also apply if the card is using a credit feature.
Terry Fitz put together a Reg. E vs Reg. Z matrix that is available in the Reg. E section on my compliance page.
If it was easy, monkeys would be doing it.
Opinions stated are not necessarily that of my employer.
[This message has been edited by Andy Z (edited 08-16-2001).]