01/04/2010
When the new Regulation E amendment becomes effective that prohibits opt-out programs for overdraft services for ATM and one-time debit card transactions, will we have to change our opt-out program for other types of overdrafts?
12/07/2009
How can we identify an ACH transaction as internet gambling when the transaction will probably have an SEC code of WEB? What is everyone doing to try to monitor for internet gambling transactions?
10/05/2009
What is the regulation (if there is one) that explains that a closed account can be reopened should a debit card or EFT/auto debit come through on a customer’s closed account?
06/15/2009
Are financial institutions required to send provisional and/or final credit notices to customers with ACH disputes under Regulation E? I'm asking because I have noticed that several banks are merely just crediting the customer's account without sending any type of notice to the customer. Also, when a customer disputes an ACH transaction under Regulation E, is the customer required to fill out an Affidavit Under Penalty of Perjury or is just a letter from the customer okay to dispute the ACH transaction?
05/25/2009
I know this is a basic question but can someone explain stop payments that are subject to Reg E?
03/16/2009
Are there any statue of limitations on a consumer filing a dispute in Reg E? The consumer comes in a year after the transactions (the first to the last transaction all occur within a 60 day period so unlimited liability would not apply) and wants to dispute the items as unauthorized. Does the institution have any defense or must they accept the loss?
02/23/2009
A customer is claiming unauthorized debits to her account. She said she just realized this, but she claims the first occurance was in May. The $200 ACH debits occured every two weeks for several months. The debits were payments on a bill she owes. She said she authorized $50 a month. I realized I only have to reimburse for the debits occuring 60 days after the statement cycle in which the error occured. So far, I am not having much luck with the third party on getting proof our customer authorized the $200. It is too late to return the ACH's for unathorized. Our customer has benifited from these ACH debits in that her outstanding debt to this company has been reduced. Can we deny that claim based on the fact the she has benefited?
02/16/2009
A customer is claiming unauthorized debits to her account. She said she just realized this, but she claims the first occurance was in May. The $200 ACH debits occured every two weeks for several months. The debits were payments on a bill she owes. She said she authorized $50 a month. I realize I only have to reimburse for the debits occuring 60 days after the statement cycle in which the error occured. So far, I am not having much luck with the third party on getting proof our customer authorized the $200. It is too late to return the ACH entries as unauthorized. Our customer has benefited from these ACH debits in that her outstanding debt to this company has been reduced. Can we deny that claim based on the fact that she has benefited?
11/07/2008
We are trying to assess the risk posed by offering remote deposit capture. Can you point us to any regulatory issuances that might be helpful? What is the associated risk with offering remote deposit capture in a US Territory…for instance the US Virgin Islands?
09/29/2008
Please clarify the following. A reoccurring ACH that is subject to Reg E can be stop paid, but it only applies to the one specific ACH. All future ACHs from the company should be paid. The stop payment does not expire in six months; it never expires. If the customer informs the bank that he has revoked authorization with the originator for a reoccuring ACH and wans all future ACHs (reoccurring authorized debits) stopped, the customer needs to complete a Revocation Form as opposed to a stop pay form and the bank must stop all future debits, if presented. A Revocation Form is different than a WSUPP form as, the WSUPP form is for a debit that has hit the account that must be returned as unauthorized/revoked entry (R07)and, language within the WSUPP form then also stops all future debits like the Revocation Form. I do not have an ACH Specialist at my bank so, any help is appreciated.