It was my understanding that E-banking/E-mail bounceback rules were repealed. Is this correct? If so where can I found this info?
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.
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.
I understand almost all of the consumer disclosure requirements do not apply to business customers. Would a sole proprietor or single member LLC be considered a consumer and receive a consumer EFT Agreement? We provide these business types a debit card in the individual's name.Are we required to provide business customers (corporations, partnerships, LLCs-with employees) with an EFT Services Agreement and/or an Agreement for Online Banking or Bill pay services?