Are we suppose to return ACHs that come in to a customer's account for a non-customer? We currently return ones that we become aware of before they hard post to the account but I didn't know if there is a Reg that governs it or if it's just bank policy.
For online banking, is it acceptable to have the EFT and eSign disclosures open as one document (both displayed on the screen in full) and then assent to both with ONE click?
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?
I am trying to find recent cost savings for converting from paper to ACH. I have been using $.80 savings for converting a credit and $.05 for converting a debit. I think these figures came from the old Fed Functional cost analysis. Any help would be greatly appreciated.
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?
Is there a federal code that requires notifing a customer thirty days before closing an account that is receiving government payments?
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?
I have a customer that opened three accounts, one for each of her children as they receive Social Security direct deposit benefits. The mother is the signer on each account and the individual child was added as an owner only because they are only nine, eleven and seventeen years of age. The mother wants debit cards in the children’s names so she can keep the account straight as to where she is pulling the money from. Can we issue debit cards to a minor and if so, would the mother have the legal right to use them? How would it be handled if the child’s card was used and they wanted to dispute the transaction?
I am going to ask a really stupid question. What is the difference between ACH and EFT? I am very new to the banking industry and these two topics confuse me.