If a customer performs transfers between his MMDA and his checking accounts using the bank's "on-line banking" product and exceeds the preauthorized limit of 6 transactions, would he be considered in violation of the reg? I would think that because he is performing the transaction himself, it would not exceed the limit (similar to using an ATM card at an ATM machine). Have you heard anything from the regulators about this?
With respect to Reg E disclosures, we will be offering online banking to our customers soon and I need to know if we need to re-disclose. (The service will be free of charge and our system will not offer bill pay. We will not open accounts online that will still be done in person. We will just be the account holding institution.) But, if I understand this correctly, we should edit our REG E disclosure to show this as a service we offer. Correct?
We are just starting internet banking and our customers will have the capability to transfer funds from one account to another. Where do we stand with withdrawal limits with on-line transfers when we have savings accounts and Money Fund accounts? Are these calculated like telephone transfers?
We are in the process of investigating Internet Banking and would like to know how transactions conducted through this product might impact Reg D transfer limitations. Are transactions done via Internet Banking considered to be "In Person"?
An elderly, disabled customer gave his housekeeper his ATM card and PIN to make withdrawals enabling her to run errands, pick up medicine, groceries, etc. She helped herself to his account in the tune of $2,300 from January through March. He filed an ATM dispute in April. Is the customer fully liable for his loss?
Can we offer debit cards to savings accounts customers? We would assume they would fall under Reg D. We are considering doing away with ATM cards
We would like to confirm that a financial institution is not required to send receipts for Voice Response transfers.
If a transfer is conducted through on-line banking product, does the periodic statement requirements (205.9) of Reg E apply?
We have a customer who primarily uses the internet and wants to stop his paper statement. We don't offer the electronic statements yet, but is there something prohibiting us from canceling his monthly paper statement?