We want to offer loan and deposit products online. What disclosure differences will we have to make?
We want to make mortgage loan applications available on our internet banking website. What are some of the issues we need to prepare for?
We have a situation where a Representative Payee on an account filed a Reg E for unauthorized ATM withdrawals. The investigation revealed that the account holder had stolen the Rep Payee's card and made the withdrawals. The Rep Payee filed a police report, but since it was only $123.50 the police aren't going to even look into it. Can we deny the claim on the basis that it is ultimately the customer's money and they benefited from it or do we need to pursue it further since under the agreement they are not authorized to access the money with the Rep Payee in place so it is truly an unauthorized withdrawal?
A customer's debit card was compromised. We properly notified the customer, canceled the compromised card and a new one was issued. Now, three months later activity has started on the compromised/canceled card. Is this considered identity theft? The customer's name was not used, just the card number. Do we need to notify the customer?
Reg E covers fraudulent transactions or unauthorized transactions not conducted by the customer/consumer, but does it provide protection for non-fraud cases? We receive a large amount of disputes where customers have purchased trials or samples from a merchant and are billed a few weeks later for additional products shipped to the consumer. We are under the understanding this is not covered by Reg E as far as provisional credit is concerned, but as long as the customer returns the unwanted products VISA grants a certain amount of protection as long as the customer did what was necessary.