Posted By: ineedhelp
Reg E Parent allowed child to use their ipad - 12/05/14 06:28 PM
A customer has come in to the bank to report a transaction as unauthorized. It was the result of allowing a child to use their IPad. these are still unauthorized but because they provided the device does that keep us from having to lose money over this? Thanks.
Posted By: Tom Owen
Re: Reg E Parent allowed child to use their ipad - 12/05/14 08:05 PM
Posted By: ineedhelp
Re: Reg E Parent allowed child to use their ipad - 12/05/14 08:09 PM
Thanks for your reply.
Yes I was thinking the same thing that they have given them the access. The only thing that was tripping me up was the fact that when regulation E was written Iphone and Ipad weren't around so those weren't in the regulation as an "access device".
That's cool of Apple to reimburse, just too bad we can't tell customers to contact Apple first.
Posted By: Tom Owen
Re: Reg E Parent allowed child to use their ipad - 12/05/14 08:15 PM
Well I see it more as the debit card is the access device, and when they put it as stored information on an ipad, and then give it to the child, they give them access. They can change settings for amazon and apple store to demand password for purchases.
Key Definitions—12 CFR 1005.2
Access device is a card, code, or other means of
access to a consumer’s account or a combination
of these used by the consumer to initiate EFTs.
Access devices include debit cards, personal
identification numbers (PINs), telephone transfer
and telephone bill payment codes, and other
means to initiate an EFT to or from a consumer
account (12 CFR 1005.2(a)(1) and 12 CFR Part
1005, Supp. I, Comment 2(a)-1
I think in extreme cases you could claim unauthorized if the parent wanted to go so far as to file police report.
One customer had his two 4 year old twins ordering toys on amazon. Technology is scary, especially how quick kids are adapting to it.
Posted By: ineedhelp
Re: Reg E Parent allowed child to use their ipad - 12/05/14 08:22 PM
Ok. I see what you are saying. Very good points. So you are saying that you would not give the customer their money back because they are considered authorized since they provided the device to the child.
Posted By: David Dickinson
Re: Reg E Parent allowed child to use their ipad - 12/05/14 10:28 PM
Be careful of this comment: "I think in extreme cases you could claim unauthorized if the parent wanted to go so far as to file police report."
You can't make a customer file a police report. The customer merely needs to report it to you, per Reg E. The bank may then file a police report.