Can a business make monthly automatic debit compulsory for payment of their product or service without offering another method of payment to the consumer?
How do you get a COT code in online transfer?
For online banking, is it acceptable to have the EFT and eSign disclosures open as one document (both displayed on the screen in full) and then assent to both with ONE click?
What are the features of ebanking?
Is the "Official Interpretations" section of Reg E subpart B Remittance Transfers part of the Reg or just someones interpretation? Section 1005.33(a)-5. i., ii., and iii. Procedures for Resolving Errors. This makes no sense to me to hold the sending bank accountable for something beyond their control. I would think an error such as this would fall under "Extraordinary Circumstances." I have to present this to our President and CFO so your answer on this would be greatly appreciated.
Does Section 4-403 of the UCC apply to ACH? I have read and read the NACHA Rule for this and Reg E. They both say that you may.
In regards to the final rule on the amendment to Reg E - Foreign Remittance Transfers, I am wondering how you interpret the official staff commentary on how to determine the number of remittance transfers provided in order to fall under the remittance transfer provider safe harbor of sending 100 or less remittance transfers in a year (1005.30(f)(2)(ii)). More specifically, do remittance transfers requested by business senders count in the 100 transfers? For example, if our bank sends 140 total remittance transfers per year, but only 80 of the transfers are requested by consumer senders (the other 60 were requested by business senders), does our bank only have 80 qualifying remittance transfers, thereby qualifying us for the safe harbor in which we would not have to adhere to the disclosure requirements of this rule?
Regarding Final Remittance Transfer Rules, if we only have 9 outgoing international wires a year, are we required to provide a disclosure?
My question relates to the definition of error in the update to Regulation E (Requirements for Remittance Transfers). If, after a sender authorizes a remittance transfer, a transaction occurs on a sender's account that reduces the amount of available funds below the amount of the remittance transfer, can the bank NOT send the transfer without an error occurring?
We offer eStatements to customers, and send an email when the statement is available. Do we need to revert to paper statements in either of the two following situations? (1) If the email bounces back, (2) the customer does not access the e-statement? Do we increase our liability in any way if we do not monitor for either of these scenarios?