We understand we have 90 days after the customer notifies us of an error to give the customer FINAL credit. ( Forget all the provisional credit stuff.) We were told by our debit card processor that we have 120 days to dispute it. They were wondering where we got 90 days. We told them Reg E and they are telling us MasterCard rules trump Reg E rules. I don't believe that. MasterCard also told us after we issue our customer provisional credit, the merchant has 45 days to dispute it. If they do not do that within 45 days the case is closed. So if after 45 days we do not hear back from the merchant and we go ahead and give our customer final credit earlier than the 90 days what do we put on our error resolution log. Do we just put no response from merchant?
I am having trouble finding software products that can track and send out notices for our Commercial loans for their yearly financials, taxes, rent rolls, etc. Any suggestions on a quick and easy solution?
We are thinking about adding loan notices (i.e. pmt notices/past due notices/ maturity notices/ rate adjustments/ etc.) to our list of items that a customer can sign up to get electronically. We already do it for deposit products (stmts and such). I realize I need to consult the applicable lending regs, most of which I believe defer to the esign act and allow for electronic delivery, but I'm just wondering if I'm missing something. I guess I'm a little nervous about sending someone's past due notice electronically even if they have to elect to receive it and confirm that they can (call me cautious). Is there anything else I need to watch out for? I am happy to do my own research but if you know of any prohibitions or can point me to something I'm missing, I would appreciate it.
Does the Durbin Amendment (Dodd-Frank Act) require all banks to adopt PIN-debit (versus signature) transaction technology?
We have a customer who has disputed a POS transaction that he DID authorize, but it turned out to be a scam. Since he did authorize the transaction, under Reg E, it is not considered an unauthorized transaction. Is this correct? I know that VISA has its own set of rules. Do you know if we are required to give him provisional credit according to VISA regs?