Reg E Claims: Just do them right! - 2019
Presented by
Andy Zavoina
Recorded on July 11, 2019
—
2.0 hours
Have you completed this webinar? Please tell us what you think.
One thing that makes me mad is when a customer authorizes a funds transfer and later finds out they were scammed. They didn’t get something for nothing, and they make a claim to get that money back from the bank. What did the bank do? 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 minimize losses by following the Reg.
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 going to a convenience store, fast food restaurant or just making any small purchase. Who carries cash? Reg E is more a part of your banking life today than in the past. 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 also continues to be a hot topic with examiners because it involves consumers' rights and funds. Reg E violations haven't generally attracted heavy financial penalties, but banks do need to be cautious. 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. One big bank recently 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 aren’t caught off guard. In some cases, management says that the bank's practices were not criticized in the past and they hadn't changed. Passing prior exams can lead to a false sense of security – Good record or not, examiners found and cited the problem. Many bankers have been taught “friendly fraud,” that is debit card use by a family member, couldn’t be claimed. Well, that couldn’t be further from the truth. How is your bank doing?
Unless your staff members who handle the process are well trained and both know and understand the regulation and the Official Interpretations, your bank is placing itself at risk.
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.
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:
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.
WHO SHOULD ATTEND:
Compliance, audit, EFT dept., Security Officer, Customer Service
Andy Zavoina
Reg E Claims: Just do them right!
Slides
Materials
Investigation Letters
EFT Unauthorized Withdrawal Workflow Form
Sample EFT Error Report
Sample EFT Notice of Error Claim Form
Attendance Sheet
Questions and Answers