Is there anything in Reg E / Opt In that prevents it from being offered to bank employees?
Reg. E contains a small bank limited exclusion for pre-authorized transfers. We still offer a passbook savings account that allows only direct deposit of payroll. There is specific staff commentary to 205.9 indicating a statement is not required in this instance. Can the argument be made that the direct deposit is a pre-authorized transfer so as a small bank we are excluded from the error resolution notice requirement?
We are making disclosure changes for the funds availability change that goes into effect July 21st. We updated Reg CC, but not sure if we have to update Reg E (cash back with deposit to ATM). Do these two items have to match? We would like to keep the ATM limit at $100 (reduce loss exposure) but we want to make sure Reg E allows it -- OR does this part of Reg E have to match funds availability in Reg CC?
What are the REG E rules concerning a delay by the cardholder of not reporting a lost/stolen card and additional transactions were processed? Example: Affidavit states card stolen 04/10, but blocked on Network 05/18.
We have a Reg E claim where the client is claiming seven transactions (the total amount disputed $5800.00). The provisional credit was issued on May 9th, 2011. On May 23rd, 2011, the merchant issued a credit directly to the client's account for two of the transactions disputed (five out of seven transactions still continuing under investigation). The amount credited $3700.00 is more than a half of the total amount of the claim. At this moment the credit is duplicate for these two trans. as per Reg E the final date for the investigation should be on July 22, 2011. Can we partially reverse the provisional credit issue (for the amount of merchant issued a credit prior to reach the final date of the investigation)?