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?
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?
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?
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?
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…