Can you provide insight into what regulatory impact, if any, is associated with ACH debit cards? For example, does this product fall under Reg E compliance?
I received a debit card application from a representative payee for an account owner. I think we can issue one, what are the risks involved?
Our lending operations department (not credit card) would like to initiate an EFT through our third party vendor to debit our customer's deposit account to exercise our right to offset for amounts owed on our customer's loan. Our deposit account terms and conditions discloses our right to offset any amounts owed to the bank. We know that generally Reg E, Section 205.3 (c)(5) would allow the bank to electronically transfer funds between a customer's accounts without the customer's specific request under certain circumstances and that the official commentary provides that this exception to Reg E includes the right to initiate "electronic debits or credits to consumer accounts for check charges, stop-payment charges, NSF charges, overdraft charges, provisional credits, error adjustments and similar items that are initiated automatically on the occurrence of certain events." In order to exercise our right to offset electronically, the transaction will need to be processed through our third party vendor. Do we have any Reg E or other regulatory concerns in doing so?
We have a case where a customer's purse was stolen including her debit card. The customer has stated that her PIN number was written in her checkbook resulting in numerous ATM withdrawals by the thief. What are the responsibilities of the customer vs the bank in this situation?
What are the rules about surcharging a EBT card in Massachusetts? As long as the user can opt-out of the charge it should be allowed, I would think. At one time there was talk about including the surcharge in the allotment.