Debit Card Compliance Maze

Recorded on May 7, 2016   |   With Brian Crow

Debit Card Compliance Maze

With Brian Crow
  • 1 Video
  • 3 PDFs
  • 2.0 hrs
Course description

ICB Credit: 2.5 CRCM

Your examiner expects you to comply with Reg E, but your issuer contract requires that you comply with VISA/MasterCard Operating Rules, when applicable. Often these do not agree, which can appear to be a no-win scenario for the institution. Misstep in one direction and the regulators are handing out UDAAP citations and fines. Make a wrong move in the other and VISA/MasterCard threatens non-compliance fines or the suspension of the card program. In addition, debit card requirements are sprinkled into several regulations other than Reg E and can easily be overlooked.

Besides worrying about how to comply with card rules and regulations governing issued cards, institutions must also concern themselves with the rules regarding cards that they acquire in the form of cash advances. Failure to comply with VISA/MasterCard procedures here won’t result in fines, but can lead to substantial fraud losses. In addition, Chip Liability Shift could impact who is responsible for counterfeit transactions. Familiarity with the requirements both as an issuer and as an acquirer are key to mitigating your risk.

Many institutions struggle with Reg E investigations. How deep do we have to dig and when do we have enough information to deny a claim? We will cover interview techniques and key red flags that can be considered when investigating a claim.

The account data breaches that have been in the news have all been related to merchants and data security failures. However, compliance is the responsibility of card issuers as well as acquirers. Learn what your institution should and shouldn’t be doing with your card data and the consequences for non-compliance.

In this webinar Brian will lead you through the maze of debit card topics:

  • Reg E liability and investigation procedures
  • Recent UDAAP citations relating Reg E
  • VISA/MasterCard Zero Liability
  • Processing cash advances for VISA/MasterCard
  • Loan payment and loan origination fee processing
  • Reg E - courtesy overdrafts and the opt-in
  • Reg E - gift card Issuance
  • Reg Z as it relates to debit card disputes
  • Reg II - network exclusivity requirements
  • Reg DD - balance disclosure requirements
  • Reg GG - blocking internet gambling purchases
  • FCRA - identity theft red flags and card issuance
  • Card data security
  • BSA/AML - requirements for general purpose reloadable cards

This program will benefit compliance officers, auditors, and operations staff with any responsibilities in the debit card arena. It will focus on the rules and regulations governing debit card programs and will not cover VISA/MasterCard chargeback procedures.

Course Curriculum

Debit Card Compliance Maze
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Brian Crow
Brian Crow

Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.

Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.

Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud. You can contract Brian at