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The Electronic Funds Transfer Act and the implementation of the Act’s requirements in Regulation E were originally penned in 1978. Debit cards, the internet, and mobile apps, did not exit. Technology has evolved, but the regulatory language has not kept pace. As the methods of accessing consumer accounts multiply, the variety of error claims under Reg E similarly continue to grow. Combine Reg E protections for the consumer with Visa/Mastercard protections for the merchant and we create a recipe for significant compliance and financial risk.
Regulation E requires that we investigate electronic funds transfer error claims, but institutions struggle with the definition of an error. Customer perception is that anything that goes wrong with a debit card transaction is the bank’s problem. Visa/Mastercard may require more information to use the chargeback process to investigate a claim than Reg E requires from the consumer to notify us of an error. Confusion over conflicting requirements can lead to violations, enforcement actions and fines.
In this information packed recording, Brian Crow offers a comparison between Reg E and Visa/Mastercard rules, a discussion of recent enforcement, and sample investigations. The viewer will gain a better understanding of Reg E’s applicability, the investigation process and investigation techniques when there are no chargeback rights.
- Reg E error definitions and coverage;
- Reg E liability calculations;
- Provisional credit requirements;
- Third party service providers;
- Debit cards and mobile applications;
- VISA/Mastercard Zero Liability;
- Reg E investigation tips;
- VISA/Mastercard chargeback rights;
- Reg E and UDAAP enforcement actions;
- Business debit cards; and
- Case studies
This recording is designed for operations staff responsible for investigating claims and compliance and audit staff who monitor error resolution