We have engaged an external IT security company to provide strong security for us. Do we still need a cyber incident response plan?
Business debit card customers do not fall under the Reg E dispute requirements but I understand they do have the same dispute rights under the VISA Rules - no liability for unauthorized transactions if reported within the required time frame of within 60 days after the statement with the unauthorized transaction. Can you direct me to the section in the VISA Rules that states that?
A customer files a claim after two months of unauthorized ATM withdrawals. The customer has possession of card, states never disclosed PIN. Withdrawals made on same days as other legitimate debit activity, withdrawals $20 - $200, ATMs w/in half mile of customer's home (customer used same ATMs in past). This is not a counterfeit situation because the customer states that her boyfriend took the card/PIN and made withdrawals and put the card back in her wallet. (High suspicion here that customer colluded, gave card/PIN to boyfriend). Under Reg E, can this claim be denied based on this evidence?
Can a representative payee have a debit card? Since they are only authorized signers, are they covered under Reg E.?
Are there any regulations that govern ATM card issuing for rep payee accounts (SSI/SSA)?
We have an EFT dispute on a Pinned ATM transaction. The customer withdrew money from another bank's ATM (which shows on her statement). She did not receive the funds. We entered a dispute on the transaction. The other banks ATM was in balance and we have been denied payment on the dispute. Under Reg E, can we reverse the provisional credit we gave to our customer?
Are there any state law caps on ATM fees? If so what states will it apply to?
If a customer chooses not to opt-in, can the bank deny them a debit card?
Is any part of ADA Website Compliance currently being enforced?
Can the time frame for error claim resolution involving an ATM (45days) be extended to 90 days if the ATM is in a foreign country, just as it can when it involves a debit card purchace transaction?