We have a customer who gave her debit card and PIN to her medical aide (she is not in good health) to assist her with groceries etc. The aide has used her debit card for purchases unauthorized by our customer. The purchases were made as far back as July, '09. What liability does our bank have towards our customer for these unauthorized purchases?
I have been informed that a change to Reg E requires us to track every inquiry about an EFT. Is this true?
We no longer accept deposits at our ATMs, so we no longer display "Funds Availability" on the screen. However, would we still need to display Funds Availability to our customers who transfer funds at the ATMs?
Our signature card currently states, "The undersigned also acknowledge the receipt of a copy and agree to the terms of the following disclosure(s): Funds Availability, Truth in Savings, EFT, and Privacy." For certain products we require e-statements. We are considering modifying the signature card to include "e-statement agreement" as part of the list of disclosures they agree to and not require the customer to sign a separate e-statement agreement. Do you see any concerns with this?
With regard to Reg E, do we have to give customers provisional credit if they say they cancelled a transaction or did not receive their merchandise/service? I know Reg E covers unauthorized transactions.