|
Question: Do we need to give commercial customers a copy of our Electronic Funds Transfer Act (Reg E) disclosures when we open an account for them?
Answer: Only for sole proprietors. This law defines "consumer" as a "natural person." Therefore, it does not apply to any entities, like partnerships or corporations. By contrast, Reg DD defines consumer as a natural person who holds an account primarily for personal, family or household purposes. That qualifying purpose language is missing from Reg E!
Question: Okay, then what rules govern error complaints?
Answer: Your contract and the system rules. Both Visa and MasterCard have explicit error resolution rules governing debit cards that limit liability. Be sure that your agreements have incorporated these revised requirements.
| 
