10/29/2012
If a customer informs our bank of unauthorized EFT transactions, can we require the customer to bring in a police report prior to refunding the amount of the unauthorized transactions?
10/15/2012
We have debit card dispute. The customer gave her card to her granddaughter to bail her boyfriend out of jail. She promised her she would have the money back to grandma's account. She used the card for the ATM withdrawal and made other transactions. The total amount is $504.99. The granddaughter did NOT put the money back in her account. So two months later grandma filed a police report. Also, she filed a debit card dispute form. My question is do we have to refund this money to the customer?
01/16/2012
We have several accounts that are set up to receive their Checking Account Statement (Paper) Annually. Are we out of compliance by not sending them a statement monthly when our disclosures state that they have 30 days from the date the statement was made available to us to notify us of any errors?
06/14/2010
With regard to the opt-in notice for Reg E debit cards NSF charges, does the correspondence need to go to all existing consumer accounts or only to the accounts with debit cards?
01/04/2010
Does a commercial customer have the same rights as a non-commercial consumer regarding ACH disputes for an item he/she wishes to be returned?
06/08/2009
Can a check for deposit be payable to the financial institution?
06/01/2009
When a customer writes a check to a third party and the third party electronically converts the check and it comes through as an ACH ARC transaction, shouldn't the bank treat these as checks and not ACH, if the system can distinguish these? Also, if the customer uses online bill payment and requests that a check be issued to a third party, should these be counted under the "6" or "3" rule? The request was made online, but a check is issued.
02/16/2009
In order for an account to be classified as "Free", does there need to be an option to receive a paper statement for free?
12/03/2007
What recourse does a business have when disputing an unauthorized ACH after the 24 hour rule? The customer claims to have no knowledge of this ACH.
08/20/2007
Our lending operations department (not credit card) would like to initiate an EFT through our third party vendor to debit our customer's deposit account to exercise our right to offset for amounts owed on our customer's loan. Our deposit account terms and conditions discloses our right to offset any amounts owed to the bank. We know that generally Reg E, Section 205.3 (c)(5) would allow the bank to electronically transfer funds between a customer's accounts without the customer's specific request under certain circumstances and that the official commentary provides that this exception to Reg E includes the right to initiate "electronic debits or credits to consumer accounts for check charges, stop-payment charges, NSF charges, overdraft charges, provisional credits, error adjustments and similar items that are initiated automatically on the occurrence of certain events." In order to exercise our right to offset electronically, the transaction will need to be processed through our third party vendor. Do we have any Reg E or other regulatory concerns in doing so?