Be sure to JOIN US on August 27, 2020, for our webinar, “Deposit Operations Overview”.
This webinar will focus on Deposit Operations regulations such as:
- Electronic Funds Transfer Act
- Truth in Savings Act
- Expedited Funds Availability Act
- Fair Credit Reporting Act
- Overdraft Hot Spots
- Unfair, Deceptive or Abusive Acts or Practices
- Complaints & Much More!
Regulation E is one of those deposit regulations that we consistently see a lot of errors.
There are a lot of timing requirements, liability calculations, etc. to wrap your brain around. One of those is the provisional credit requirement.
Click on the video to listen to Jerod explain more.
Read the Transcript Below!
Let’s talk about walking around money. Hi there. This is Jared Moyer with Bankers Compliance Consulting. I know, I know. What in the world’s walking around money? Well, here let’s do this. The regulation is the Electronic Funds Transfer Act, specifically unauthorized transfers covered by the Electronic Funds Transfer Act. Now there’s two sections in regulation E, the Electronic Funds Transfer Act, that deal with unauthorized transfers. There’s 1005.6, which is the baseline. And then there’s this other section, 1005.11, that is a little bit better deal for the customer if they do things in a quicker timeframe.
So it works like this, if the consumer tells you about the unauthorized transfer within 60 days of the statement on which it first appears and you ask them to put it in writing within 10 days and they do, and you aren’t able to complete the investigation within that same 10 days, then you have to give them what we call walking around money. You’ve probably heard it referred to as provisional credit. The idea is this — since you couldn’t complete the investigation during the initial 10 days after being notified, hey, and now you’re going to take the extended timeframe, which the regulation allows for, in order to take on the extended timeframe.
If you’ve asked them to put it in writing and they did, you have to give them walking around money. They get to walk around with the money in question in their pocket, until you complete your investigation. If you complete it in their favor, they get to keep that money. And if you don’t, you’re going to end up taking it back and there’s rules surrounding that. But that’s what walking around money is. We have a lot of different reg E and other deposit related training available within our library on our website, bankerscompliance.com. We’d love to have you reach out to us and figure out how we can partner with you to get the best solution in your hands, so that you can get your team going in the right direction. Pick up that phone and give us a call today.
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