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CFPB PUBLISHES EFT FAQS

On June 4, 2021, the Consumer Financial Protection Bureau published eight Electronic Fund Transfers FAQs. The Frequently Asked Questions address: Do fraudulent inducements constitute “unauthorized electronic fund transfer?” In a fraudulent inducement has a consumer furnished an access device under Regulation E? Can negligence by the consumer be used as the basis for imposing greater liability than is permissible under Regulation E.? Can an agreement restrict a consumer’s rights beyond what is provided in the […]

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REGULATION E ERROR RESOLUTION AND POLICE REPORTS – NEITHER THE TWAIN SHALL MEET?

During a recent Regulation E training event, the class and I discussed the Regulation E Section 1005.11 “Procedures for resolving errors” and there, as always, was very active discussion of what a bank may request, but not require. I brought up the prohibition against requiring police reports as a requirement for the bank to either begin the investigation provision or to provide provisional credit and there were a number of questions.  Many banks have in […]

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