Most Popular Technology Content
Merchant Capture Device - Reg D Transaction Limits
01/07/2008
In your article on Reg D, <a href="http://www.bankersonline.com/compliance/gurus_cmp080502o.html">Transfer of Funds: Do sweeps count against the transaction limit?</a>, you pointed out unlimited transactions between accounts at the bank, done at an ATM, in person, made by mail and Direct Customer Contact. Now where does the merchant capture device fit in this picture, since you have basically taken the bank to them with direct access to move money between their accounts. It seems the customer is standing in front of a piece of equipment very similar to an ATM. Should these transactions count?
Customer's Recourse with Merchant
01/07/2008
If a customer pays with a debit card, what recourse do they have when the product they purchased is no good and the merchant will not give refunds? The receipt did not disclose "No Refunds, Exchanges Only". Does it make a difference if it was used as a credit card where they signed for the merchandise instead of using the PIN?
Reg E - Temporary Reversal of OD/NSF Fees
01/07/2008
When providing provisional credit to comply with Reg E, are we required to temporarily reverse OD/NSF fees?
Parent's Debit Cards, Minors & Internet Purchases
01/07/2008
We continually receive disputes involving minor children (under age 18) who have purchased a product on the internet using their parents debit card number for payment. The parent files a claim for unauthorized transaction. Obviously, they refuse to get a police report as we normally require to continue the investigation. The parent tells us the child made the transaction, but they (the parents) did not authorize it. Can the fact that the parents are responsible for actions of minor children living in their house and using their equipment be our defense for denying the claim?
Reg E Question Follow-up
12/17/2007
The passage below is part of John Burnett's response to a Reg E question concerning unauthorized transactions reported beyond 60 days from the statement delivery date. For example, if there was an unauthorized transaction (no access device used) that appeared on the customer's June statement and he or she is just now reporting it, must the bank reimburse the customer? My bank has been denying these claims as too old. Based on everything I've read, I believe the customer is not liable for these initial transactions, even though they appear on earlier statements. I am wondering what John meant by "unless the transaction is one in a series" in the article below. Could someone elaborate please? Your consumer/customer is entitled to enter a claim with you that an entry was unauthorized at any time (the 60 day limit in section 205.11 only covers the customer's right to the procedures in that section, not the customer's liability for unauthorized transfers, which is found in section 205.6). If the transaction is unauthorized, the customer is entitled to a refund unless the transaction is one in a series and took place more than 60 days after the statement was available that showed the first unauthorized transaction in the series.