Reg E - How to Handle Customer Disputes and Inquiries
Tuesday, May 8th, 2012
PREVIEW QUESTION: A customer reported that they lost their card. The customer told the personal banker that they'd written their PIN on the card. There have been several ATM withdrawals that the customer reports weren't done by him. Isn't the customer liable since he wrote his PIN on the back of the card? Our account disclosure says that the customer agrees to keep their card and PIN secure. Can we deny the claim?
ANSWER: The consumer's liability will be determined by whether or not they reported the loss of the card within the prescribed time frames. Unfortunately, the commentary to Reg E 205.6(s) says this: "Consumer negligence. Negligence by the consumer cannot be used as the basis for imposing greater liability than is permissible under Regulation E. Thus, consumer behavior that may constitute negligence under state law, such as writing the PIN on a debit card or on a piece of paper kept with the card, does not affect the consumer's liability for unauthorized transfers."
Presenter - Susan Costonis|
Susan Costonis is a compliance consultant and trainer. She frequently provides consulting services to financial institutions regarding fair lending and other compliance management issues. Her 34 year career in banking and training began with 20 years at First National Bank, an affiliate of Wells Fargo Bank, in Fort Collins, CO. Susan has been a bank compliance consultant or compliance officer in Louisiana since 1998. During her career, Susan has successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve. She is a Certified Regulatory Compliance Manager and completed the ABA Graduate Compliance School and the Graduate Banking School of the University of Colorado. Susan regularly presents seminars to financial associations.
Who Should Attend?
Customer Service Reps, New Account Reps, Teller Supervisors, Deposit Operations staff, Security and Compliance Officers will find this session very beneficial. NOTE: This webinar will NOT address Visa or MasterCard zero liability rules.
© 2011 All rights reserved, Site Design by Eric Kellough