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Reg E - Definition of Point of Sale Transaction

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Question: 
I work for a third-party service provider for financial institutions in the compliance area for credit cards. I am trying to get my hands around a procedure due to non-compliance and there is no definition of POS that I can find. The problem is that I am fighting with the manager regarding the error resolution 45-day requirement vs the 90-day requirement. She is telling me that everything we do is POS and I need to verify that. My thoughts about a POS were that it was always a pin-based transaction and if you use your debit card as a credit card through Visa or Mastercard it falls into the Reg Z realm. Can you help me with this?
Answer: 

If it is a credit card, the transactions are subject to Reg Z. If it is a debit card, whether authenticated by signature or by PIN, POS transactions are subject to Reg E's error resolution rules which allow up to 90 days for a claim to be resolved. If the transaction is an ATM withdrawal made within the US, the cap is 45 days. Transactions made outside the U.S. (and territories) or in a new account, even at ATMs, can be resolved in up to 90 days.

First published on BankersOnline.com 3/16/09

First published on 03/16/2009

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