Electronic Funds Transfer Act (Reg E)
What does reg E require of non-remittance transfer disclosures?
Clear and understandable
How many days does a sender for a remittance transfer have to tell the bank an error was made?
180 days after the disclosed date of the availability of funds
Reg E imposes a change that increases fees or charges, how many days in advance of the change should they notify customers?
21 days (think Credit Card grace period, 21 days)
Provisional credit is made to customer and notify customer NO LATER THAN how many dats after the bank receives noticed of alleged error?
45 calendar days to investigate plus 3 business days to notify the customer
How long must the bank honor checks payable to third parties after the transmittal of the notice of investigation?
5 days
What is a remittance transfer?
A US sender to a designated recipient in a foreign country
When is a change in terms notice required?
A reduction in services
Examples of EFT
Direct deposits, POS, ATM transfers, payments made by bill service
Does reg E cover business transactions?
No
EFT includes what types of funds transfers?
POS, ATM, telephoned transfers, direct deposits, payments made by a bill service
What must a bank due once a customer notifies them of an unauthorized transfer of funds?
Provide provisional credit within 10 business days and take up to 45 days to investigate the unauthorized debit.
Which type of transactions can the bank assess overdraft fees without giving the required disclosures and getting affirmative opt-in consent from the customer?
Recurring payments using a debit card and ATM
Unauthorized withdrawal of funds with proper PIN were used, what should the bank do?
Review problems, assess the location of the transaction in relation to customers pattern of use, review historical patterns
What is the timing of initial, non remittance transfer disclosures?
When the customer contracts for an EFT service or before he first EFT is made.
What is an EFT?
electronic funds transfer - any movement of funds by means of an electronic terminal, telephone, computer or magnetic tape
Under Reg E, which of the following pieces of information must be included on an ATM receipt?
location of the terminal
Notification of lost debit card and liability
notify within the first 2 business days, responsible for $50, otherwise $500
When an entire transaction is conducted orally by telephone (e.g. debit $300 from my account and sent to her sister in Peru); what is the bank's responsibility?
provide an oral prepayment disclosure at the time of the request and the receipt information on the next account statement.