With regard to website changes (disclosures, marketing advertisements, general changes, etc.) is there a concrete retention schedule or best practices for retention? I see many companies treat these changes like a hard copy advertisement change. They will print out the archived page and save it for the examiner. If this is the case, is there a time frame to keep these archived print outs or do you just save them between examinations? I couldn't find any information on the FFIEC website that explains a policy and any website research is very vague.
We have a client who has an unauthorized debit card transaction in his account. The client refuses to close the card because of other pre-authorized transactions he has already set up through it. If more unauthorized transactions come in from the same place as the original one, is the bank still liable for the loss even if the client refuses to close the card?
Are there any examples of debit card dispute errors that would guide us on what type of disputes the banks must file or not file? One of our biggest dispute areas is when a customer goes online and signs up for a 14 day free trial product. All of these websites have terms and conditions that state if you don't cancel before the end of the trial period, you will be charged the full amount for the product and they ship your next order. Then the customer disputes the larger charge as unauthorized and most of the time keeps the product that was mailed to him/her. Are the banks responsible for even taking this type of dispute? Seems like the customer has entered an agreement with the merchant and this should not be of any interest to the bank.
We had a customer ask us to replace a damaged card. She never received or reported that she didn't receive her replacement card. In the mean time, the new and old card are being used. Three months pass before she discovers and reports to the bank that she did not get her replacement card. Is she liable since she did not report this to the bank? She knew she asked for a replacement card; knew she didn't get it, and never contacted us.
We are in the process of adding external account transfer capability (A2A)to our Internet banking service. Our vendor indicates that these transactions will show on our statements as Internet-initiated transactions and all transactions will display our own bank name. It is my contention that the statement should indicate the name of the other institution and I believe Reg E 205.9 (b)(1)(v) supports this. Of course, since it would only be logical to have the name of the other F.I. on the statement, it probably isn't required.