Most Popular Technology Content
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?
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?
Electronically Delivering NSF & OD Notices
12/17/2007
We've debated offering NSF or overdraft notices (the postcard when an account overdraws and overdraft protection kicks in) in electronic form rather than in writing via postcard or letter. Is there a regulation that NSF or overdraft notices are required to be delivered in writing to the customer? The transaction is clearly noted on the periodic statement as required. We feel that delivering electronically (via email or secure message) provides a more timely notice to our customers, therefore enabling them to prevent further overdrafts. However, we want to ensure we aren't violating any regulations that requires the notices be in writing. Please advise.