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Disclosures for New Debit Card Program

We are starting up a new debit card program. I need help on what policies I need to make sure that I include in our debit card program. Prior we only offered ATM cards. What disclosures do I need to be mailing out? I figured I needed to mail out new EFT disclosure and Reg E disclosure. What kind of offline limits do I need to set for our customers? Is there a Regulation on that?

Answer by John Burnett: You are correct saying that you need to provide a new Regulation E EFT disclosure. You can either include the information on the debit card EFT provisions in your overall Reg E disclosures or create a separate document for the debit card product. As for offline limits (often called stand-in authorization limits), there's no regulation that dictates what they must be. Your service provider or network may have suggestions on the dollar amounts to use, and should also give you the option of not providing stand-in authorizations. You'll have to review the network's up-time record and the risk involved in allowing stand-in authorizations to make a risk-based decision.


Answer by Brian Crow: VISA and Mastercard have disclosure requirements regarding their Zero Liability programs and cross-border transaction fees. These should be included in your cardholder agreement. Check with your network processor or forms vendor as they may be able to assist you with the required verbiage. Finally, make sure that you incorporate the Zero Liability provisions into your dispute resolution procedures.

First published on 10/22/12

First published on 10/22/2012

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