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One thing that makes me mad is when a customer authorizes a funds transfer and then finds out they were scammed. They didn’t get that great discount and maybe didn’t get anything at all, so they make a claim to “get that money back from the bank.” But what did the bank do? The bank didn’t give their money away. Regardless – the bank must now investigate the claim.
E-commerce and mobile banking have contributed to the rise in transactions, and claims. One fact is you will lose money with each claim. Between processing the claim, the investigation and deciding to pay or refuse a claim, the amount you lose is controlled by the claim and by you. You must find the balance between what to pay and when, and it must be in compliance with Reg E or your risk of loss is even greater. This webinar is designed to help you understand Reg E claims and pay what is required, no more, and no less.
Your banking delivery channels have changed and that means you need more attention on Reg E. More of your customers are using an electronic funds transfer when getting home delivery, going to a convenience store, a fast food restaurant or just making any small purchase. Who carries cash? Reg E is more a part of your banking life today than ever. Worse yet, there are more ways to lose, from card cloning to skimming, to theft from an “authorized user.”
The proper handling of Reg. E error resolution claims is critical. It continues to be a hot topic with examiners because it involves consumers' rights and money. Reg E violations haven't generally attracted heavy financial penalties, but banks do need to be cautious because nobody wants to hear, “please re-review these claims” during an exam. But one bank was fined $82,500 for violations under not Reg E, but UDAAP - Unfair, Deceptive or Abusive Acts or Practices. The bank was investigating Reg E claims differently than they were disclosing. Another paid a $3.5M civil money penalty and $12M in restitution. Why? In part it failed to handle Reg E claims correctly. We will discuss claims in depth so you mitigate risk and protect your customers and the bank.
We will discuss when vendors are responsible for the Reg E claim – not your bank. And what about “friendly fraud,” when a debit card is used by a family member? Some say that’s not a valid claim but that couldn’t be further from the truth.
Bank staff members handling this process must be well trained and both know and understand the regulation and the Official Interpretations to reduce risk and comply.
In this information-packed webinar, you and your staff will see Andy demonstrate a free program that can help your bank both investigate Reg E claims and manage/audit them for compliance. He'll discuss the four time periods available to you in the investigatory process and how to determine which applies to each claim. You'll get information on critical issues in the resolution process, such as provisional credit, customer notifications, amounts to be refunded, and when and how much may be withheld from any refund. These are topics examiners are laser focused on and the CFPB addressed on it’s June Guidance Document.
The regulatory wording controlling the claims process is complex and can be confusing. This confusion can lead to claims that are paid in the wrong amount, incorrectly denied, or paid late. These errors can be costly and embarrassing when you are required to correct them after a regulatory exam. Recurring errors can also cost you in the form of penalties imposed and file reviews required by regulatory exam reports.
On the other hand, your staff may be paying claims that could legitimately be denied. There is no reason to "take the easy way out" and pay claims unnecessarily, particularly when doing so can unnecessarily cost your institution thousands and thousands of dollars. The information uncovered in your investigation doesn't always make this balancing act easy. This webinar is intended to help you use the results of your investigation effectively to make a more informed decision.
During the webinar, Andy will discuss:
- when the Reg E rules apply
- when a vendor has to handle Reg E, not the bank
- the four investigation time periods
- interim steps required during your investigation
- when provisional credit is required
- determining how much to pay a customer
- tips for determining valid claims from denials
- required error resolution notices, written and otherwise
- when notices must be provided
- finalizing claims and reversing provisional credit.
You'll also receive sample letters that you can adapt to ensure consistency in your written error-resolution correspondence.
This presentation will include claim examples, discussed step-by-step so that you can see how to apply the regulatory requirements – using a free Excel program – to claims from your customers. You'll complete the webinar with a better understanding of the claims process.
Reg E has requirements that must be followed. But there are many twists and turns on accepting claims and processing them. Doing this wrong because “that’s how the guy before me said to do it” is dangerous. Learn what the rules really require.
Please note that a basic understanding of Reg E is assumed and that ACH, MasterCard and Visa rules and procedures for debit card claims will not be addressed during this session.
Error Report - 1
Error Report - 2
Error Report - 3
Questions and Answers