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#567162 - 06/14/06 03:19 PM Upgrade ATM to MasterCard debit
ddiver Offline
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Joined: May 2006
Posts: 83
If I have interpreted Reg E correctly an access is solicted if the consumer requests it. So our ATM card customers have already requested the access device. We are now going to mass reissue MC debit card to replace these, and send new Reg E disclosures and the MC aggreement with the mailing detailing how to activate.Seems right? Or would this be an unsolicted issue as it is a different product they did not request, but are now basically forced to accept and we follow the unsolicted issuance of acces device guidance?

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General Discussion
#567163 - 06/14/06 04:45 PM Re: Upgrade ATM to MasterCard debit
Compliancer Offline
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Joined: Jan 2006
Posts: 334
San Francisco, CA
It is okay to send out the cards in the way you have described so long as the cards are not active. Providing activation details, such as a call-in number from the home phone, is sufficient since once the consumer calls in, they are in essense requesting the card to be activated (the sending of the unactivated card is really nothing more than advertising).

You cannot force them to take the card, but you are not required to issue an ATM card either. I'd recommend your bank examine the customer impact for consumers that choose not to activate the MasterCard debit card but now will be without an ATM card.
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#567164 - 06/14/06 09:06 PM Re: Upgrade ATM to MasterCard debit
ddiver Offline
Member
Joined: May 2006
Posts: 83
So then would this be considered an unsolicted device because it is a new type of card, or would we consider this an accepted device because they have an ATm card already. I just want to make sure the letter has all the reguired information for an unsolicted card if this is the case.

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#567165 - 06/21/06 11:03 PM Re: Upgrade ATM to MasterCard debit
Compliancer Offline
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Compliancer
Joined: Jan 2006
Posts: 334
San Francisco, CA
The ATM card is a separate access device. You need the consumer to agree to a new one since it is not the same one (a new ATM card is not a new device). It is unsolicited to start, but it's also inactive so you are not violating Reg E. - also nothing can be done with the card until it is activated anyway. The act of activating it in essense then means it is solicited.

It's no different than if you mailed a debit card application to the consumer and after he/she reviewed and completing it, you show up knocking on the door the next minute with the newly activated card in hand.
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My opinions do not necessarily reflect those of all the voices in my head.

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