Reg E - Debit Card Applications - Required or Not?

Posted By: brainOverload

Reg E - Debit Card Applications - Required or Not? - 01/23/09 10:25 PM

Is a written, signed application required in order for a debit card to be issued? I see Reg E states that a financial institution may issue an access device to a consumer in response to an oral or written request for a device but I just want to make sure. I belive that our auditors allways ask to see our signed applications from customers.
Posted By: BrendaC

Re: Reg E - Debit Card Applications - Required or Not? - 01/23/09 10:43 PM

No. Reg E provides for the following:

Unsolicited issuance. A financial institution may distribute an access device to a consumer on an unsolicited basis if the access device is:
(1) Not validated, meaning that the institution has not yet performed all the procedures that would enable a consumer to initiate an electronic fund transfer using the access device;
(2) Accompanied by a clear explanation that the access device is not validated and how the consumer may dispose of it if validation is not desired;
(3) Accompanied by the disclosures required by Sec. 205.7, of the consumer's rights and liabilities that will apply if the access device is validated; and
(4) Validated only in response to the consumer's oral or written request for validation, after the institution has verified the consumer's identity by a reasonable means.
Posted By: brainOverload

Re: Reg E - Debit Card Applications - Required or Not? - 01/23/09 11:06 PM

Thank you, I read all of that but, what does it mean?

Right now we take an application that must be signed. A card that is not activated is then issued and mailed to the customer with all of the proper disclosures and the information on how to activate the card. The PIN is send in a different mailing. We are trying to determine if the written and signed application is even necessary and I cannot determine that from what I am reading...
Posted By: rlcarey

Re: Reg E - Debit Card Applications - Required or Not? - 01/23/09 11:20 PM

It is not necessary, as like the regulation states, it can be an oral request. It is just an internal control function and makes life a lot cleaner, but that decision is up to the bank.
Posted By: brainOverload

Re: Reg E - Debit Card Applications - Required or Not? - 01/23/09 11:30 PM

Thank you...this will please the Gods!