A business debit cardholder filed a dispute. Since businesses are not covered under Reg E, what time frames apply? Do I need to have it resolved in 5 days, do I give them provisional credit? I am uncertain what rules to follow!
There was a question in the Infovault about charging non-customers a fee for performing a cash advance when using a VISA credit card, which appears to be prohibited per VISA participation rules. However, would there be any issue with charging an ATM surcharge to all non-customers making cash advances at an ATM using a credit card (so long as an onscreen notice for the amount of the surcharge allowing the customer to cancel, was present)?
Does a Reg E claim need a written customer signed statement to be keyed out to the other institution/merchant?
If our ATMs are in offline mode (ATM is able to perform transactions but is not communicating with the host system), the customer's opt-in selection is not available to the ATM. The customer's withdrawal transaction is completed using an offline transaction limit assigned to the card. This means that a transaction could be completed even if there are insufficient funds in the account. If the customer did not opt-in and does not have enough money in the account, the transaction will be completed anyway. We don't charge the OD fee if the transaction posts and actually results in an overdraft, but we essentially have not honored the customer's opt-in choice. How is everyone else handling this when a customer complains he was allowed to overdraw?
Can we state this on our Reg E disclosure? I don't think so but wanted to bounce it off you:"The use of web enabled phones (smart phones) for access to Internet Banking is currently not a product offering. ABC Bank shall not incur any type of liability related to the use of web enabled cell phones for accessing Internet Banking."