From: Nelson, David M.
Sent: Tuesday, July 01, 2003 11:32 AM
To: regs.comments@federalreserve.gov; Comments;
regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
While I
was conducting Regulation E (Electronic Funds Transfer)compliance
examinations, I noted that error resolution procedures sometimes conflicted
with NACHA rules. Regulation E provided a bank with less time to investigate
and resolve an error, while NACHA rules allowed for a longer period of time
for EFT service providers to investigate and resolve errors. This requires
the banks to resolve an error before they may get all of the information from
the service provider to make a determination. The bank would have to credit
to a customers account before all the information was provided. Later they
might find out from a service provider that the error was different, but it
would be too late. I know that Regulation E is made to protect consumers, but
maybe NACHA rules and Regulation E can be reconciled somehow to help the banks
resolve the errors more accurately and reduce charge offs.