We have received several ATM REG E disputes stating that the "ATM" they used dispensed counterfeit currency. All of my usual contacts at peer banks and the ABA are extremely divided on whether these are REG E disputes or not. Just looking for more advice....
Our customers are being charged a fee to convert foreign currency to US dollars when they use an international ATM. This fee is charged by the network and passed on to our customers. Do we need to disclose this fee in our Reg E disclosure?
Reg. E- VISA recently revised their current exchange rate disclosure and notified banks that it is replacing the currency conversion fee with an International Service Assessment of 1%. The letter we received said we must notify our debit card holders of this change by April 1. Does Reg. E require us to provide the 21 day notice in this instance where the fee is assessed by a 3rd party such as VISA. In the past this fee was assessed directly to the customers account but now we have the choice of absorbing the fee or passing it on.
Are we required to monitor Internet Bill Payment transactions for CTR reporting?
What is the rule for a bank web site to list currency rates? Should there be a disclaimer added on the page or can it be contained in a privacy statement elsewhere on the site?
by Dr. Michele Petry, Editor, BankersOnline.com