Community Bank Compliance
In today’s banking environment as soon as one big new regulation is implemented another pops up. Our compliance resources help your community bank stay one step ahead of the regulators.Regulations and Guidance
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Compliance Question of the Week
QUESTION: If the bank issued an unsolicited access device and the device is used for unauthorized transfers, is the consumer responsible?
A bank may not impose liability on a consumer for unauthorized transfers involving an unsolicited access device until the device becomes an "accepted access device" under the regulation. A card and PIN combination may be treated as an accepted access device once the consumer has used it to make a transfer.
Reference: Official Staff Interpretation 1005.5(b), comment 2.