First Scenario: a customer's ex-husband knew her account number and online password, went into her account and withdrew all her money. Customer notified the bank within 24 hours. REG E legitimate claim, right?

Second scenario: customer's ex knew her account number, went online and set uponline banking for the express purpose of withdrawing all funds. Again, customer notified bank within 24 hours--legitimate claim also under the same REG E reasons?

First Scenario: Possibly not. Had the customer previously given the login information to her ex? If so, had she notified you that he was no longer authorized to use it?

Second Scenario: I don't think you have an out on this one. Additionally, assuming the ex had to enter personal information (name, SSN, etc) belonging to your customer in order to apply for online banking, that's identity theft, and should be prosecuted as such.

Thanks for your help, Jac----first scenario: the customer had not given the login info to her ex. He evidently guessed what her password was and already knew her account number from pre-divorce.

Okay, just to bump one more time, even if she had her login info sitting on her computer and she claims she did not make the withdrawals, wouldn't that warrant a REG E investigation regardless? I think there is some confusion looking at a pin for a computer as an access device.

Okay, just to bump one more time, even if she had her login info sitting on her computer and she claims she did not make the withdrawals, wouldn't that warrant a REG E investigation regardless? I think there is some confusion looking at a pin for a computer as an access device.

In short, the transaction falls under REG E because ity was completed using an electronic delivery channel. The login id/password does count as an access device under Reg E. So yes, this claim does need to be handled according to Reg E.

I'm curious- how were the withdrawals completed? ACH to another bank?

Through bill pay. Talk about messy divorces which create fraud!