NCJ Number
83168
Date Published
Unknown
Length
0 pages
Annotation
A summary is presented of examination procedures regarding the issuance by financial institutions of access cards (i.e., debit cards, personal identification numbers) for the purpose of electronic fund transfers.
Abstract
Bank examiners should consider whether access devices contain credit features since regulation E applies if electronic fund transfer features are issued with the card and if cards with both electronic fund transfer and credit features are issued if the only credit privilege is a preexisting overdraft). Regulation Z generally applies when a combination credit/electronic fund transfer card is issued and when an access card (with no credit features) is issued. Examiners should obtain and review all form and notice requirements: disclosures and receipts, periodic statements, account agreements, error resolutions, and change-in-terms notices. These records must be stored for 2 years. Examiners should identify which personnel are responsible for compliance with regulation E, test the bank's practices against written policies, and review consumer complaints at the reserve bank and in the bank itself. They should check the bank's error resolution procedures and check whether the bank understands the requirements of regulation E. Finally, examiners should ensure that the bank has a procedure for halting electronic fund transfers when an unauthorized transfer occurs and determine whether the bank adheres to liability limits.