All in Regulation E

Over the years, we have seen a number of questions relating to how Regulation E error resolution rules relate to pending transactions that have not yet settled to a customer’s account.  The challenge that many bankers face is a customer will call in to dispute a transactions they see on their account as a “memo post,” but since the transaction is pending, it may never actually post to the account or will be finalized in an amount different than the original “memo post” amount. For bankers, this is challenging because…

On 1/2/19, new CFPB director Kathleen Kraninger signed a consent order with USAA Federal Savings Bank.  While the consent order outlines millions of dollars in restitutions and penalties, the order provides financial institutions with fairly detailed insights on a number of Regulation E violations identified by the Bureau.  As Regulation E applies to all financial institutions regardless of their regulator, this consent order can be used as a learning tool for appropriately complying with the Regulation.

Specifically, the USAA consent order outlined six main deficiencies that resulted in either a violation of Regulation or a UDAAP violation, or both, including…