Regulation E. Timely notice not given question? We often have customers file debit MasterCard claims 6 months or more past the date of the "unauthorized" transactions. Regulation E would have the bank responsible for the first 60 days from the statement date. What if we have proof of Online Banking activity or that the customer accessed their E-statements, during and/or after the disputed transactions? Would the liability now fall on the customer, or are we still responsible for the first 60 days unless proven authorized?
If a customer "opts in" to have their statements provided in their online banking, are we obligated or regulated to send them a paper statement AND online statement the 1st month their statement cycles?
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 The thought is naturally that the error will be detected and the amount withdrawn.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?
A Q and A dated 10/26/09 by Richard Insley "E-Statement Agreement" states the following,"Although you are free to require e-statements as a condition of a new product, you can not require existing product-holders to relinquish paper statements and accept e-delivery." What regulation does this statement come from?
I have a debit card dispute on 52 transactions (all from the same merchant) with dates ranging from 9/26/10 thru 11/21/10. This customer states that the merchant contacted her about the possibility of fraud on 11/19/10. On that same date, she contacted our bank and had her card cancelled. She did not file a dispute with us until 1/26/11 because she claims she has been working with this merchant to resolve the dispute. My question is, what date should be used in determining the 60 day statement guideline for provisional credit? Should we consider 11/19/10 as the notification date, or 1/26/11?
We have accounts that have debit cards. Can we still make a requirement that restricts paper statements from being delivered? Can we make it a requirement to have e-statement or none?
We offer e-statements to customers. When someone signs up, he is provided the Reg E disclosure electronically at that time. Do we need to have a link to the disclosure for future reference, and specifically, the Reg E part of reviewing a statement for errors? Would a link be sufficient for people to access at any time if the language is not included on each statement?
We are deciding whether or not to provide e-statements on our internet site. What are the required disclosures needed to provide this service? I understand that the customer can choose whether or not to receive his/her statement electronically.
We are starting the process leading up to electronic statements. I asked that marketing offers be optional links. I would like compliance issues, such as notices of change, to be prominent either at the top of the statement page and/or appear automatically and require action on the part of the customer to move past the notice. I don't know yet what I will get. If we have the technology to obtain customer consent to receive electronic statements, I would think this would be a piece of cake. Of course, I am not a programmer. How are others handling this?
When a new member/customer enrolls in e-statements, are we required to present images of prior statements, or only statements produced after their enrollment?