A hold was placed on a deposited check that the bank received by mail. The bank was unable to reach the customer by phone, but mailed the hold notification the same day. The customer contacted the bank by email a week later, upset that he wasn't notified at the time the hold was placed. He stated he received the notification three days after the deposit was made. Would it have been acceptable to notify the customer by email if the message was not detailed, but stated something to the effect "Please contact (bank employee) at (bank name) concerning a hold."?
We want to make mortgage loan applications available on our internet banking website. What are some of the issues we need to prepare for?
Where can I get information on compliance related to emailed DDA/SAV statements? We need to know if the customer has to pick up the email in a certain number of days.
As it relates to Reg E claims, I need clarification:<ol><li>is an internet purchase considered a POS<li>is a telephone purchase considered a POS</ol>I'm trying to utilize the POS 90 day extension time period. The reg is not straight forward in this regard.
According to Reg E, do we have to block a member's card if we receive mail back marked wrong address? We have been doing this and I can't find the wording in Reg E that supports it.
We have a member who said she returned a product via mail, so we submitted a charge back under 53. The merchant says the product was not returned. The member’s dispute was for defective merchandise. Under Visa regulations, do we have to take the loss on this?
We are thinking about offering E-deposits to customers. The customer would go into the home banking application, enter the amount of the deposit and the check information then physically mail us the paper check. The customer would receive immediate availability on deposits up to a specific limit. Once checks are received (within 5 days) we verify the check information and process the checks normally, but do not post the funds. If the checks are not received in time, we can extend the time requirements. What type of transaction is this considered and which regulation does it follow? Reg D, DD, E or Z? Do we have to provide special disclosures and if so, which ones?
We are considering sending an email newsletter to our customers with general financial news as well as product promotions. Can we send a first issue to all customers for whom we have email addresses without violating the CAN-SPAM regs?
If a customer has signed up for e statements and we find that the customer has not retrieved his statement in 60 - 90 daus, is there a Reg E issue with availability of his periodic statements?
In your article on Reg D, <a href="http://www.bankersonline.com/compliance/gurus_cmp080502o.html">Transfer of Funds: Do sweeps count against the transaction limit?</a>, you pointed out unlimited transactions between accounts at the bank, done at an ATM, in person, made by mail and Direct Customer Contact. Now where does the merchant capture device fit in this picture, since you have basically taken the bank to them with direct access to move money between their accounts. It seems the customer is standing in front of a piece of equipment very similar to an ATM. Should these transactions count?