Reg E and Third Party Providers

Answered by:

Question:

Our customer was careless and gave his account info out. After that, fraudulent transactions happened as a non-bank provider who doesn’t have an agreement with the bank processed transfers from the consumer’s account at our bank. Can we push the customer off to that payment provider to get their money?

Answer:

No, you can’t. Your bank will meet the definitions that require you to provide consumer protections, not a company your customer had no contract with.

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Learn more about Andy Zavoina’s Reg E Guidance – EFT Compliance webinar.