Reg E overdraft questions from the January 6, 2010 webinar:<ul><li>Does the reg allow you to offer the option of opting in to ATMs or to debit cards in addition to both? <li>For existing clients, can the confirmation be sent at the same time as the written notice, maybe with a tear-off section with the revocation information that the customer would keep? <li>It talks about the telephone being an acceptable method to obtain the opt-in. How would this work through a call center? Would the call be sufficient or would a written notice have to be mailed and received before taking any action from a called in request?</ul>
With the new amendments to Reg DD in 2009 about ATM balances including ODP amounts, is it enough to have separate balances, i.e. Ledger Balance (actual) and Available Balance (including ODP)? That is what we have currently. I just want to make sure we are in compliance if the available balance doesn't actually state that it includes ODP.
Is there a user-friendly form or template that we can use for the opt-in or opt-out choices regarding the overdraft coverage?
To be in compliance with Reg E, how would we handle this type of situation: if a chargeback has been initiated on a transaction, but the expiration exceeds the last date we have to finalize (45 or 90 days), do we have to make a decision with the member before we know if the claim is approved or denied? If so, how would we handle representments after the fact? Particularly when it's represented because a member is contractually obligated.
We offer commercial debit cards. One of our clients recently had fraudulent activity of POS transactions in another state. Our Debit Card Contract with our customer states that the client is responsible for any loss due to fraud and the bank is not liable. The customer is not happy that he is liable. I can’t find anything that states the bank would be liable. I just want to double check to make sure we are correct in thinking this way.