Reg E Scam Claims
09/19/2021
If a consumer is scammed and instructed to purchase gifts cards and give the scammer the card information, is this covered under Reg E?
Andy Zavoina
Bio:
Andy Zavoina, CRCM, is an Executive Vice President and Chief Relationship Officer with the Glia Group, Inc., best known for its interest in BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for 35 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy is a frequent webinar presenter for BOL Learning Connect and a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting https://www.bankersonline.com
Mr. Zavoina has been in finance and banking for 35 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy is a frequent webinar presenter for BOL Learning Connect and a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting https://www.bankersonline.com
Contact info:
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting http://www.bankersonline.com.
Questions Answered
Reg E Claim Denied-Prior Transfer
09/19/2021
Can we deny a p2p transfer dispute (such as CashApp) if the customer is claiming fraud however, the customer has sent money in the past to that same payee previously?
Filing Police Reports on Losses
09/12/2021
For police reports, if the bank is taking the loss on large dollar amount claims, can the bank file a police report?
Reg E Claim Requires Bank Form
09/12/2021
It has been my experience that most financial institutions request a consumer sign a specific form (vendor developed; card processing developed; or internally developed) - what I would consider "industry standard." I have a client who was cited by the FDIC (who said "all" regulatory agencies are citing this as an issue) for "requiring the use of a particular form." Regulation E allows for requiring disputes be put in writing and signed, providing the investigation is not delayed if a written form is not received. The bank's process includes beginning the investigation upon notification (oral or written) and follows up with getting a specific form signed (card processor developed). Has anyone else heard of regulators citing for "required use of a specific form"? If the card processor requires disputes be submitted on their form, how can the bank complete the investigation process without "requiring" the use of a specific form?
A bake sale by any other name…
09/12/2021
Every year we do a bake sale to raise funds for Breast Cancer Awareness/Local Hospital Foundation. Is this acceptable?
Reporting winners to the IRS
09/12/2021
We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?
Paying Timely Provisional Credit
09/05/2021
For signature card transactions, is the Bank required to give provisional credit by the 5th business day?
Lottery Exceptions
09/05/2021
Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups- post lobby posters or sell tickets for or be a sponsor, etc.?
Small Business Loan NPRM Immanent
09/05/2021
Is use of a general AAN turndown reason such as: “Unqualified co-applicant” considered specific enough for Reg. B compliance or should a general turndown reason like this be avoided?
AANs on joint applicants
09/05/2021
Joint application is received by the bank with one applicant having excellent credit and the other having terrible credit. For AAN purposes, if we provide the specific reasons for turndown to the terrible applicant such as repossession, delinquent past/present credit obligations with others, etc. and then provide an AAN to the excellent applicant, we should re-state repossession, delinquent credit obligations, etc. on the excellent applicant’s AAN as well - even though these reasons don't specifically apply to the excellent applicant himself, but are the primary reasons for the turndown. Correct?
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