Topic: Electronic Fund Transfer Act (EFTA)
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What language should we use when notifying customer about the new MasterCard zero liability rules for PIN based transactions that are going into effect on October 17, 2014?
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We believe that your institution should provide change in terms notices to any customers who will be affected by the MasterCard rule change. Because the MasterCard rule change could increase a customer’s liability for unauthorized transactions, the change must be disclosed. Regulation E requires a change in terms notice at least 21 days before the…
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Does Regulation E apply to business customers? What about small businesses? Do business accounts have any requirements for error resolution?
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The Electronic Transfer Fund Act (Regulation E) does not apply to your business customers. Regulation E applies to “any electronic fund transfer that authorizes a financial institution to debit or credit a consumer’s account.” 12 CFR 1005.3(a). The term “account” is defined as “a demand deposit (checking), savings, or other consumer asset account . .…
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Do we need to disclose the foreign (out-of-network) ATM fees that our institution charges on our Regulation E disclosures? Can we instead disclose the fees on a separate fee schedule?
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We believe that you must disclose the out-of-network ATM fees charged by your institution, but the fee disclosure can be included on a separate fee schedule that complies with Regulation E and Regulation DD’s disclosure requirements. The initial account disclosures required by Regulation E must include “any fees imposed by the financial institution for electronic…
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If a customer applies for a debit card after opening an account, do Regulation E disclosures need to be given out again?
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Yes, we believe you must provide new Regulation E disclosures every time a customer adds a new electronic fund transfer (EFT) service to an account. Regulation E requires that you provide new disclosures whenever a new electronic fund transfer service is added to a customer’s account, if the terms and conditions are different from those…