Answer:
Answer by Andy Zavoina:
While you may contract with a third party to perform certain services, you are ultimately responsible for the products and services being delivered properly to your customers. And regulatory compliance, in this case Reg. E, is your responsibility.
Answer:
Answer by Lucy Griffin
Yes, you are responsible for Regulation E errors. You cannot transfer regulatory liability. However, you can provide through your contract with the thirdparty provider that they will take on your liability. In other words, you are responsible to the consumer, but you can by agreement pass on the costs and responsibilities for corrective action to a third party.
First published on BankersOnline.com 3/05/01
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