Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#2189933 - 08/21/18 04:45 PM REG E disputes and ATM deposit
ComplyMI Offline
New Poster
Joined: Aug 2017
Posts: 5
We have several ITMs that function as ATMs after hours when staff is not available. They will image individual items, including cash for deposit into a customer account. There have been several times the machine has jammed and the transaction cancelled, but all of the cash was not returned to the customer at the terminal. An account was not affected and no "transaction" actually occurred. Would any of you consider that situation to be an EFT dispute?
If so, can you provide a brief explanation?

Return to Top
Operations Compliance
#2189961 - 08/21/18 06:06 PM Re: REG E disputes and ATM deposit ComplyMI
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Credits are EFTs, too. Definition of an EFT 1005.3(b)(1) The term “electronic fund transfer” means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account.

Reg E Definition of error 1005.11(a)(1)(iii). The omission of an electronic funds transfer.

The customer states that their accounts should have been credited the amount of the cash that the machine kept. The credit isn't there (omitted). Yes, this is an EFT error.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top

Moderator:  Andy_Z, John Burnett