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#1473864 - 11/30/10 07:07 PM Business Debit Cards and Opt In
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
We're getting ready to offer a business debit card:

Does the Opt In rule apply? Or is that a direct correlation of whether or not you choose to apply your Reg E procedures to the business card program?
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#1473995 - 11/30/10 08:54 PM Re: Business Debit Cards and Opt In RBanker
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
Reg E does not cover consumer accounts so you would not need to solicit opt-ins from your business debit card customers if you offer overdraft privledges to you business accounts.

I would advise against applying Reg E procedures to business cardholders as you place the bank in a greater liability position.
Business debit cards will still be covered by VISA/MC's Zero Liability protection and you can utilize similar chargeback procedures to your personal cards, but VISA/MC chargeback procedures are not bound by the investigation timeframes that Reg E requires.
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