We are adding ebills to our edocument service. If a customer chooses to receive an e-bill for their mortgage, all other accounts will be converted to e-statements as well. Is this considered a violation of the ESIGN Act as the customer is only signing up for the mortgage bill?
Our software vendor made a change in the software requirements for our customers to be able to open and read an E-statement. Our agreement with the customer when E-statements was launched advised the customer that they needed Adobe Reader 6.0 or higher to be able to read their statement. They now need 8.0 or higher to be able to read it; they can no longer view it in 6.0. Am I correct that this is a material change and 101(c)(1)(d) of ESIGN must now be complied with? My software vendor does not have the functionality in their e-statement product at this point to comply with 101(c)(1)(d), which is a another problem but they are also advising me that going from one version of Adobe Reader to another is in their opinion not a material change because when the customer attempts to open an estatement they will be prompted to download the latest version of Reader for free. I disagree, the customer may not be able to download it and under ESIGN they must demonstrate to the bank that they can still open and read an estatement.
A customer completed a dispute form for an unauthorized Visa transaction. Per the customer, she paid cash and only provided the merchant her debit card number as backup. The card was not supposed to be charged. I received a report back from the chargeback center stating that there were no chargeback rights unless receipts were submitted and an explanation of any differences in amount. I asked for a document retrieval to see if the customer had signed a contract. I was contacted today and told that it was a card not present transaction so there were no documents to retrieve. I cannot get the customer to contact me regarding receipts paid. What are my options under both Reg E and Visa rules?
We offer eStatements to customers, and send an email when the statement is available. Do we need to revert to paper statements in either of the two following situations? (1) If the email bounces back, (2) the customer does not access the e-statement? Do we increase our liability in any way if we do not monitor for either of these scenarios?
Prior to transfer to CFPB Reg E disclosure requirement under 205.3(b)(2)(iii) retired on 12/31/2009. However, CFPB Reg E 1005.3(b)(2)(iii) does not mention the disclosure is no longer required as of Dec 2009. Does this mean the CFPB has re implemented this disclosure requirement?
Are there any kind of charges for individual eBanking?
What are the requirements for terminal location on periodic statements when it is a debit card purchase from a website?
Under Reg E if provisional credit is removed due to a merchant refunding in full, does the FI still have to cover checks and OD Fees for 5 days?
Are we required to send a quarterly statement to our Passbook Savings customers if there are no electronic transactions that post to the customer's account? We have a Statement Savings account that a customer can use for ATM transactions and to set up electronic activity and we do send the required statements monthly if there is electronic activity and quarterly if there is not, but on our Passbook Savings, since we update the passbook each time a customer brings it into the bank we only generate a statement if the customer has an electronic transaction post to the account. The Passbook Savings cannot be accessed with an ATM card, but we do not block a customer from setting up an electronic transaction.
We have a customer that is highly disabled and unable to take care of herself without outside help. She needed cash and gave her ATM card to this person along with the PIN so that she could get cash. The helper withdrew unauthorized additional funds. Our customer filed dispute with us. My questions are we released from giving her funds back since she gave the PIN? Also, can we make her file a police report and press charges against the person or we'll withhold her funds?