A to Z of Reg E - 2018
Presented by
Andy Zavoina
Recorded on August 10, 2017
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2.0 hours
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ICB Credit: 2.5 CRCM
Reg E remains in the compliance spotlight, after all, it is a consumer protection. UDAP penalties have been imposed numerous times because of a disconnect between what banks disclosed for Reg E and what it actually did. The offending institutions received negative press, adding “insult to injury” atop the Civil Money Penalties they had to pay and the increased scrutiny in future exams.
Sometimes you need to pause, take a breath and look at the forest. That is why I invite you to join me on a review of Reg E from disclosures, to procedural requirements, to claims. We always include claims in our discussions of Reg E because that is often where the day-to-day stress is. But you also have to understand what your disclosures say and how you actually “do” what you disclose. There are basic questions that I see again and again such as “the card and PIN were given to a person, so they have authority to use that card forever, right?” Wrong! And “family fraud” isn’t a valid claim, right? Wrong! Are you up to date? Your examiners are, and they’re asking pointed questions during exams because they know where the problems are.
It is a fact that debit card use is still increasing. This increase in volume means an increase in claims. When there is a financial loss, who loses? You already know that the bank does! But there is more than one way to lose money on a claim. Do you have to investigate all claims? No. Are you charging off more in losses than is necessary? Maybe. Are there big penalties against banks for handling Reg E the same way they have for years? You can bet on it! “That’s the way we’ve always done it” doesn’t work when it’s wrong.
Reg E has many disclosure requirements, including those related to overdrafts, and there are rules for the issuance of an access device, liability disclosures, gift card rules and contract issues when you offer a branded debit card.
In this webinar, we will discuss the basic Reg E requirements and then there will be a focus on claims for unauthorized withdrawals from a customer's account. You must know when a claim is valid and has to be paid, and when it is not. Otherwise, you are cheating the bank, or the customer.Andy Zavoina
A to Z of Reg E
Slides
Materials
Error Report
Error Report - 2
Investigation Letters
Questions and Answers
Claim Workflow