05/20/2013
Could we use your model disclosure for Check 21 to use at our institution?
06/11/2012
Under Reg E if provisional credit is removed due to a merchant refunding in full, does the FI still have to cover checks and OD Fees for 5 days?
05/28/2012
If a consumer enrolls in bill pay and has their account electronically debited for the payments, and then the bill pay company converts the electronic withdrawal from the customer's account into a paper check to be sent to the vendor identified, (1) do these transactions (the electronic withdrawal from the consumer's account) fall under Reg E coverage, and (2) if the check payment is sent to the wrong person/company by bill pay because the customer did not update information in the bill pay system, is the customer responsible to work through the company that received the payment in error or is the bank responsible under Reg E? The transaction was authorized with the customer inputting the information.
10/10/2011
We are getting ready to open accounts online. Do we require the signature card printed, signed, and returned to bank? Many banks do not. What are the legal concerns if we do not have a signature on file?
09/05/2011
We have accounts that require two signatures. When the customers have gone to places such as Walmart or Sam's Club, the check was scanned and handed back to them and a draft presented. Therefore, the signatures could not be verified. It's not the customers' fault, but we in turn, return the check for the reason "two signatures required" which I don't agree with but what else can we do?
08/08/2011
How do I process third party cashier checks electronically? I have a merchant account services that allows me to submit my checks (business, personal, cashier, bank draft) via a program. The problem is that the check goes to the bank for processing under my business name and not the payee name.
02/28/2011
If a provisional credit is reversed because the customer contacts the bank and acknowledges the charge, is the bank required to monitor the account for 5 business days?
10/18/2010
We were just notified of the death of one of our debit cardholders. He passed away over the weekend. The person who told us about his passing is an authorized signer (not a joint owner) on our customer's account, and also has a debit card that accesses the account that she used to do shopping and other errands for our customer, who was often too ill to go out on his own. We know that we have to watch the account and stop paying any checks our customer drew once ten days have passed since his date of death, but what do we do about transactions conducted by the authorized signer, by check or by debit card?
06/07/2010
As long as our system can support it, are we allowed to offer an opt-in (courtesy pay) on just debit transactions, but not ATM or PIN POS transactions? Our opt-in will be to a courtesy pay program which will allow the member's debit transaction to be authorized for up to $300 above their available limit. Can we set criteria to qualify for the courtesy pay, such as requiring the member to be current on all loans, be eighteen years of age or older, maintain a direct deposit of $100, bring negative balance current within a week, etc? Do we need to have a separate courtesy pay program for ATM/Debit transactions, or can we have one program, which covers all types of transactions, including checks, ACH, ATM, Debit, etc., as long as the member opts in for the courtesy pay for ATM/Debit transactions?
05/24/2010
We have received conflicting advice on whether we can require customers to opt-in to the Reg E overdraft fees in order to receive a debit card. Can we or can't we?