VISA OCT Transaction

Is a VISA OCT transaction considered a Reg E covered transaction?

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A VISA Original Credit Transaction is covered by Reg E. The definitions for EFTs and POS terminals include debits and credits.

1005.3(b) defines an EFT. Although not an ACH, an OCT certainly would be covered by item iii. “Direct deposit or withdrawal of funds.”
(b) Electronic fund transfer. (1) Definition. 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. The term includes, but is not limited to:
(i) Point-of-sale transfers;
(ii) Automated teller machine transfers;
(iii) Direct deposits or withdrawals of funds;
(iv) Transfers initiated by telephone; and
(v) Transfers resulting from debit card transactions, whether or not initiated through an electronic terminal.

Also look at the staff interpretations to 1005.3(h) defining an electronic terminal. It covers debits and credits.

2. POS terminals. A POS terminal that captures data electronically, for debiting or crediting to a consumer's asset account, is an electronic terminal for purposes of Regulation E even if no access device is used to initiate the transaction. See § 1005.9 for receipt requirements.