When Reg E does apply, what kind of requirements can we place on the customer? Can we require that they file a police report or prove they have attempted contact with the merchant first?
How can we shorten the time limits in regards to a customer reporting a problem in for Reg E? Our card agreement requires provisional credit in five business days, so we want the customer to be forced to notify us sooner.
When I have fraud on an account, I send out fraud documents to the member and require they be signed and returned before we can get credit back. If the member never signs the documents and time expires to do this, does the credit union have any recourse for the member, can we charge it back to them legally or does the credit union have to take the loss? What should be done?
Does Regulation E require you to send dispute resolution letter with all information regarding the transaction, or can we send a generic letter? "Your claim is denied ,"or "your dispute is valid" with no information regarding the date and amount of the transaction? I was always under the impression you had to provide that information in a closure letter.
We discontinued offering prepaid cards a year ago. Customers can still use any previously purchased prepaid cards until the card expires or is cancelled. Customers can continue to reload their prepaid card but not through the bank. Is there any applicability for us regarding the new Prepaid Card Rule effective April 1, 2019, such as the error resolution provision for example?
Regarding the following question I read today, would it be okay for a bank to charge the overdraft fee if the customer HAD opted in - even though the
account had a positive balance when the transaction was approved? Or, does this fall in line with the UDAP statement from the agencies?
Can we charge an overdraft fee for a one-time debit card transaction that overdraws an account of a customer who has not opted-in if there were
sufficient funds at the time of authorization but not at the time the transaction posts?
No. The rule does not include any exceptions for card transactions that overdraw an account. The rule at its simplest is, "No opt-in, no overdraft
I have heard that business accounts do not fall under Reg E. How does this apply to internet banking and what about a business account that is a sole proprietorship?
If a consumer purchased tires and later claimed they were defective and they filed a Reg E claim, but refused to go back to the merchant, can we deny his claim?
What are your thoughts on debit cards for children under 18, when the account is joint with a parent?
In regards to fraudulent debit card charges, the bank I work at in California requires our customers to try to get the money back (even though it's fraud) before they will file the claim. From working at other banks, it was always my understanding that when it's a fraudulent charge, we file the claim and the customers do not have to try to get any money back. Are we in violation by requiring them to contact the stores/vendors to try to get money back? We haven't come across any situations where the vendor can even bring up the charge since it's not in our customer's name and we don't have any order number or anything.