Corporate Debit Card Disclosures

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Question:

We are considering offering a debit cards to our corporate accounts, what type of disclosures will be needed?

Answer:

I'd recommend two different forms of notices (I won't call them disclosures, because that term suggests a legal mandate to provide information, and that's not the case here). First, I would state clearly that the account and its owners are not protected by the Federal Electronic Fund Transfer Act or Federal Reserve Regulation E, or by [insert the name of any state consumer-protection in EFT law/regulation here], even if the customer should happen to receive information about consumer protections for users of the cards. Second, I would have a carefully-crafted (with legal counsel's advice) card agreement that states the rights and responsibilities of the customer and the bank with regard to issuance and use of the card(s).

First published on BankersOnline.com 8/27/07