What does “integrated” document tracking mean?
We’re not sure we offer any mobile financial services (MFS). Can you give us some examples of what these are?
Our operations department wants to consider implementing the following: all customers who have signed up for e-statements will receive any NSF notices via email. We have an encryption system (Zixmail) available, so they would likely go out that way. Would this be covered under our existing e-statement disclosure, or should we have those customers sign a second authorization?
Regarding automated telephone banking systems, customers can currently inquire (get account balance and info) by phone with their account number and last four digits of their SSN. If they want to transfer funds between their accounts, they must complete an application. My bank wants to give automatic access to transfers too. I'm concerned about Reg E issuing access device rules. Is calling the number and following the steps, "requesting" the access? We have new operations personnel who say all banks do this automatically. Other banks don't have customers fill out a form or call and talk to someone, it is all done through the automated phone system. Does this comply?
We've heard conflicting reports from the many webinars we've attended regarding Reg E. If we send out opt-in forms on May 1, do we have to begin waiving fees at that time, or can we give our customers the 8/15/10 effective date and begin waiving then?
We have many customers who signed up for estatements on only one account, even though they may have multiple accounts with us. Operations would like to make it mandatory for those customers that currently have estatements, to have estatements for all accounts that are held under that customer's name. I don't think we can force this issue, that the customer must authorize estatements, correct?
We have a POS debit coming through one of our accounts that was not authorized by the bank. It was declined NSF, but I am being told that we can not return a POS no matter what. In this case, the merchant forced the POS knowing that it was declined, so why should the bank have to pay for it? Where can I find the rules that govern this kind of transaction?
Our lending operations department (not credit card) would like to initiate an EFT through our third party vendor to debit our customer's deposit account to exercise our right to offset for amounts owed on our customer's loan. Our deposit account terms and conditions discloses our right to offset any amounts owed to the bank. We know that generally Reg E, Section 205.3 (c)(5) would allow the bank to electronically transfer funds between a customer's accounts without the customer's specific request under certain circumstances and that the official commentary provides that this exception to Reg E includes the right to initiate "electronic debits or credits to consumer accounts for check charges, stop-payment charges, NSF charges, overdraft charges, provisional credits, error adjustments and similar items that are initiated automatically on the occurrence of certain events." In order to exercise our right to offset electronically, the transaction will need to be processed through our third party vendor. Do we have any Reg E or other regulatory concerns in doing so?
A customer has a monthly insurance premium set up to automatically be debited from his or her checking account. The customer comes into the bank and wishes to place a stop payment on the ACH draft. If we load a stop payment order to their account, what should our expiration date be? Our normal expiration date on a check is 6 months. Our deposit operations department seems to think we can only guarantee a stop payment on a draft for 1 month. Is this correct and what regulation answers this question?
Our Reg E disclosure states that the limit for point of sale transactions is $500 per business day, however, we have officers that want to increase the limit for some customers. I am concerned about discrimination issues since the limit would not be the same for all customers. It would appear there could be other operational issues as well if there were unauthorized transactions or stolen cards. Are my concerns valid?