Are there any regulations that govern ATM card issuing for rep payee accounts (SSI/SSA)?
Can an institution accept a deposit by matching a name or social security number if the account number is invalid?
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.
I have a customer that opened three accounts, one for each of her children as they receive Social Security direct deposit benefits. The mother is the signer on each account and the individual child was added as an owner only because they are only nine, eleven and seventeen years of age. The mother wants debit cards in the children’s names so she can keep the account straight as to where she is pulling the money from. Can we issue debit cards to a minor and if so, would the mother have the legal right to use them? How would it be handled if the child’s card was used and they wanted to dispute the transaction?
Are there any regulations or laws out there that deal with giving a debit card to a foreigner without a social security number? I am having trouble getting started.
I am wondering if anyone has any knowledge of what the generally-accepted definition of "substantially regular intervals" is in terms of preauthorized EFTs under Reg E - is it at least every 60 days as is mentioned in 205.10(a)(1)?
For an account which electronic fund transfers can be made, may the bank send a notice each time with the date, amount, source and account number and not the other information that would be on the monthly statement as opening and closing balance in place of a periodic statement for each monthly cycle in which an electronic fund transfer has occurred? In particular, on a savings account that is normally sent a quarterly statement when no EFT activity has occurred, will the notice mentioned above suffice for a direct deposit to the account in place of the monthly statement?
My mother has a credit union savings account into which her monthly social security payment is directly deposited. But she only receives a quarterly statement on the account. Aren't credit unions subject to the same statement requirements under Regulation E that my bank has to follow?
I recently heard about an FDIC rule regarding the use of social security numbers for logins and/or passwords to access accounts online. I have tried to find more information regarding this but have been unable to come up with anything.
For security purposes what minimum requirements should be set to establish an Internet home banking account relationship over the Internet, i.e. should we require the individual to input their account number, Social Security Number, date of birth, mothers maiden name, or what other info at a minimum, to establish the account? Is there any regulatory guidance on this?