A person makes out a deposit slip at the ATM to deposit $3,000.00 into their bank account. The ATM system immediately credits their account for the $3,000.00. They also receive credit for the $3,000.00 when the deposit transaction is retrieved from the machine. They don't notice for a few days until they check their online banking that $3,000.00 was credited to their account twice. Upon looking at the statement, it shows that there were two $3,000.00 deposits in the account. The thought is naturally that the error will be detected and the amount withdrawn. It has now been fourteen (14) months and has shown up on two bank statements. The questions: 1) Is there any law covering whether or not the money becomes the property of the account holder after a certain amount of time, and if so, what rights does the account holder have? 2) The account gets closed say after ninety (90) days, and the error is still not detected, but they find it fourteen (14) months down the road. Would they be able to pursue legal action?
Is online banking available for accounts that require two signatures?
Our internet banking crew wants to allow on-line accounts to be opened without requiring the signature card. At this time, we have been sending the account documents to the customers and requiring them to send back a signed card. I'm not comfortable with this concept without having an agreement with a customer we have never seen.
With all the new advances in online banking, what are the rules concerning online banking transfers between two business accounts (corporate, LLC, partnership) with two different tax ID numbers, but both are owned by the same person?
Many of our commercial clients originate ACH files and some transactions get returned for insufficient funds, etc. When an ACH transaction is returned to us, we charge it back to the client’s account, much like we do for returned checks. We have a couple of clients who have asked for an individual ID to appear on our ACH Return Notices, along with appearing on the transaction itself (though DDA and/or Online Banking history), and appearing on the DDA statement. We have a procedure in place that stops this information from printing on the original ACH transaction for consumer clients. Many of them complained, since this field may contain social security numbers. There is no regulation on what has to appear in this field. It may contain a SS number, but may also contain other information. I have seen a mix of things in this field ranging from a blank field, to a person’s name, to a string of numbers and letters that do not mean anything to me. Basically, we hide this field from consumers due to their complaints. The situation I am asking about is slightly different, but I would still like to confirm with you that there are no regulatory or privacy issues. For the custom we are getting ready to ask for, it will show the information that is in this field, it will show it on the actual return notice, it will print it on the statement, and will also appear through DDA and OLB history. The difference here though is that the client who sees this information on his return notice and on hus statement is the same client who populated that field, so I do not think it will be an issue, since it is information that the client provided to us originally, and that he already has access to it, but I wanted to double check before we get too far down this road.
Can an electronic account notification, such as an "NSF" notice, substitute a paper one and be sent to customers via email or online banking under either Reg DD or Reg E?
Please explain "simple customer agreement" regarding electronic consent for the ATM/1-time debit transaction opt-in?
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."?
Our institution sends E-statements to its members. With regard to 12 CFR 205.9(b)(5) and listing the address and telephone number for inquiries, is this required to be directly on the statement, or can we include this within our online banking module or via a message to the member when we send notification that their statement is available?
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?