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Regulation on Processing Codes and Transactions

Answered by: 
John Burnett

Question: 
We went live with our debit cards in May of 2011. We just recently discovered errors in our processing codes. We have several accounts that have transactions for the last 12 months that did not post to customer accounts. We have corrected the error but have numerous transaction that we need to clear from our non-processed account. I'm not sure if we can process the whole 12 months or just go back six months (thinking stale dated check after six months). Is there any regulation that would prevent us from processing all of these transactions? We have the cardholder statements and also the copies from our processor that show the transactions were approved but not posted to their accounts.
Answer: 

Once you are certain that the transactions were completed by the customers, you can post them without regard to the date they were completed. You will make some customers unhappy, particularly those that may have believed they were getting away with something. However, there is no "stale" date on these transactions, and it would be unjust enrichment for any customers whose transactions didn't "catch up with them."

First published on BankersOnline.com 9/24/12

First published on 09/24/2012

Filed under: 
Compliance
Filed under compliance as: 
Debit Cards
IT
Statements

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