A friend received a letter from their banking institution which informed that they would no longer offer debit cards on business accounts because of changes to Dodd-Frank. I am not aware of this. What Regulation is changing?
In regards to ACH credit entries, is it okay to place a client's credit into a holding account if the original account was closed but the client also has other active and open accounts?
In regards to the final rule on the amendment to Reg E - Foreign Remittance Transfers, I am wondering how you interpret the official staff commentary on how to determine the number of remittance transfers provided in order to fall under the remittance transfer provider safe harbor of sending 100 or less remittance transfers in a year (1005.30(f)(2)(ii)). More specifically, do remittance transfers requested by business senders count in the 100 transfers? For example, if our bank sends 140 total remittance transfers per year, but only 80 of the transfers are requested by consumer senders (the other 60 were requested by business senders), does our bank only have 80 qualifying remittance transfers, thereby qualifying us for the safe harbor in which we would not have to adhere to the disclosure requirements of this rule?
Is the "Official Interpretations" section of Reg E subpart B Remittance Transfers part of the Reg or just someones interpretation? Section 1005.33(a)-5. i., ii., and iii. Procedures for Resolving Errors. This makes no sense to me to hold the sending bank accountable for something beyond their control. I would think an error such as this would fall under "Extraordinary Circumstances." I have to present this to our President and CFO so your answer on this would be greatly appreciated.
Does Section 4-403 of the UCC apply to ACH? I have read and read the NACHA Rule for this and Reg E. They both say that you may.