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One of the many ways that technology is changing and challenging our business is through the use of electronic payments. Despite this, many agencies have yet to create a clear policy on how to handle electronic payments. What steps should you be taking to stay compliant?
Firms need to consider the differences between various kinds of electronic payments and how to avoid collection errors that can cost you real money. There are some practical ideas you can implement that will help you improve your electronic payment compliance, and, over time, limit your company’s regulatory exposure and reduce the overall cost of litigation.
This workbook distills the information presented in our Policies and Procedures webinar. It comes complete with a link to the full recording of the webinar as well as the slide deck and full transcript of the webinar. This workbook doesn’t just walk through what agencies should and should not be doing, going forward – it contains the full Q&A from the webinar, too.
Product: PDF Download, including link to webinar video, slide deck, and full transcript of the webinar
Pages: 69 pp
Table of Contents
- How to Use This Guide
- Why Create an EFTA/Regulation E Policy?
- What Format is Best for EFTA/Regulation E Policies and Procedures?
- What Key Elements Do EFTA/Regulation E Policies and Procedures Need?
- Key Elements: Purpose Sample Text
- Key Elements: Scope Sample Text
- Key Elements: Statement of Policy Sample Text
- Key Elements: Procedure Sample
- Key Elements: Responsibilities
- Key Elements: Documentation Reference
- Key Elements: Other Useful Sections of a Reg E/EFTA Policy and Procedure
- Where Policy and Procedure Documents Should Be Kept
- Appendix A: Q&A from the Webinar
- Can we set a minimum payment for electronic payments
- How long is the CFPB’s look-back period?
- When a borrower falls behind on payments and needs to create a new schedule, do you feel that the original EFT authorization is sufficient? Or would we need to have a new E-sign for EFT drafted and executed prior to proceeding with the new payment schedule?
- Can a live person taking payment log recording tones as authorization? Or is a separate IVR program required under the E-sign requirements?
- Where do prepaid debit cards fall with regards to Reg E?
- We do check writers, but deposit those checks into our bank through a scanner provided. Is this considered EFT, since we are creating an image to deposit into our account?
- Are prepaid cards EFT? Because we tell people to just get a prepaid card and load funds onto the card
- Appendix B: Slide Deck
- Appendix C: Transcript from the Webinar
- Appendix D: CFPB Compliance Bulletin 2015-06:
- Requirements for Consumer Authorizations for
- Preauthorized Electronic Funds Transfers