Time Frame to Return ACH for Business
04/01/2013
If a check on a customer account is returned nsf/and then the customer comes in to stop payment on the check, is that allowed? What are the legal kinds of stop payments?
Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.
Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.
Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud.
See all Upcoming and On-Demand training presented by Brian.
You can contract Brian at b_crow@tcaregs.com.
04/01/2013
If a check on a customer account is returned nsf/and then the customer comes in to stop payment on the check, is that allowed? What are the legal kinds of stop payments?
04/01/2013
Our customer gave their 9-year-old child permission to buy a book on the Internet through Apple ITunes in the amount of $9.99. While in the website the child was looking at a lot of other things. Next day 12 charges came through their account totaling $373.44. They want to dispute as they only authorized $9.99. When they talked to the child he said he looked at lots of stuff but had no idea he was purchasing what he looked at. The parents called the number on statement and it directed them to a website which they emailed. We told them to let us know when they hear back which could be 48 hours. Can they dispute the difference?
04/01/2013
We are a small community bank that does not offer an overdraft program. We elected to opt out of the Reg E amendment effective July 1, 2010 and are paying one time debit card transactions that overdraw accounts without charging an NSF fee. Obviously we are losing income because of this. We are wondering if we could charge a reactivation fee on the debit cards that have overdrawn for the second time. Example: customer overdraws account with one time debit card transaction. We suspend the card. The customer deposits and we unsuspend. The customer does it again, we suspend, they deposit and we charge a reactivation fee to reactivate the card the second time. Is this ok? If not, can we charge an annual fee on debit cards?
03/18/2013
Is it OK to require police reports when consumers file EFT disputes?
03/18/2013
Under Reg E or MasterCard if a customer has multiple disputes a year, are we required to give provisional credit or can we refuse provisional credit if there is suspicion?
03/11/2013
Does Reg-E cover transactions for consumers if they enter into a free trial and fail to cancel within the time limit expressed in the terms and conditions of the free trial?
03/11/2013
We have had a large number of card compromises, MasterCard. Transactions conducted as credit/signature transactions. What recourse do we have with the Merchants who accepted these cards to begin with?
03/11/2013
I am trying to find classes or training to get the most complete information on doing PIN-based disputes. Please tell me where to look.
02/25/2013
I recently went to a seminar and during it they mentioned that we should issue a TISA and Reg CC disclosure to any potential customer inquiring about our accounts regardless if they open an account or not. Is it a violation if that is not done and they are only issued to customers opening accounts?
02/18/2013
We have an EFT dispute on a Pinned ATM transaction. The customer withdrew money from another bank's ATM (which shows on her statement). She did not receive the funds. We entered a dispute on the transaction. The other banks ATM was in balance and we have been denied payment on the dispute. Under Reg E, can we reverse the provisional credit we gave to our customer?