Another wish list item that stands on its own: Regulation E provisions, specifically, its treatment of negligent consumer behavior.
Under the regulation, consumer behavior that may constitute negligence under state law, such as writing the personal identification number on a debit card or on a piece of paper kept with the card does not affect the consumer's liability for unauthorized transfers.
The extent of liability is determined solely by the consumer’s promptness in reporting the loss or theft of the debit card (or other access device).
Credit unions also find applying Reg E’s tiers of liability to be major challenge, to say the least, especially when timely notice is not given and multiple transactions are involved.
Lastly, many fraudsters are quite skilled in manipulating the rules, causing substantial losses to credit unions and other financial institutions. This is a major frustration for credit unions dealing with assertions of ATM/debit card fraud.
Want to add to this wish list? CUNA’s Compliance Community is the perfect place to share sample policies, tips, tricks, and anecdotes of what works and what doesn’t at your credit union.
It’s also the best place to stay up to date on finalized rules, amendments, and newly updated and released agency guidance through CUNA’s CompBlog, where CUNA’s compliance staff provide compliance-related updates.