Can you provide insight into what regulatory impact, if any, is associated with ACH debit cards? For example, does this product fall under Reg E compliance?
A customer has a monthly insurance premium set up to automatically be debited from his or her checking account. The customer comes into the bank and wishes to place a stop payment on the ACH draft. If we load a stop payment order to their account, what should our expiration date be? Our normal expiration date on a check is 6 months. Our deposit operations department seems to think we can only guarantee a stop payment on a draft for 1 month. Is this correct and what regulation answers this question?
I am wondering if anyone has any knowledge of what the generally-accepted definition of "substantially regular intervals" is in terms of preauthorized EFTs under Reg E - is it at least every 60 days as is mentioned in 205.10(a)(1)?
With regards to electronic banking, what is the definition of pre-funding?
Should a bank allow ACH transactions on home equity lines of credit that are generally accessed by a check? Consider that some checks are converted to an ACH transaction. Under what Regs would these types of transactions be governed and what is the risk to the bank and to the consumer?
What regulations should be considered as we write our Remote Capture policy (Check 21, Reg E, Reg CC, etc.)?
Should business entities with different Tax ID numbers be permitted to make internal transfers via online banking?
A business who is a customer of the bank has entered into an agreement with the bank to collect bad checks. The bank initiates an EFT to collect the check and reimburse the business. At the same time the check is collected the bank initiates a fee to the consumer's account for the bad check and the bank keeps the fee. From what I understand, the bank is sending the fee on its own behalf. Wouldn't the bank be responsible for giving a notice under the new Reg E effective Jan 1, 2007 to the customer in this instance?
I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
I had heard that congress was going to pass an internet gambling bill but I haven't seen it. Has it passed? If so where can I find it?