Steve H. Powell & Company

  • Contact
  • About us
  • Management
  • Services
    • Loan Review
    • Compliance
    • Due Diligence
    • ALLL Methodology
    • Strategic Planning
  • Newsletter
  • Blog
  • Contact
  • About us
  • Management
  • Services
    • Loan Review
    • Compliance
    • Due Diligence
    • ALLL Methodology
    • Strategic Planning
  • Newsletter
  • Blog

​

Rising Interest Rates and Regulation E

6/13/2018

0 Comments

 
By: Brian Taylor

As interest rates slowly climb back to pre-2008 levels, financial institutions are encouraged to evaluate the effects of a rising rate environment on deposit compliance. Specifically, banks should assess how rising interest rates impact their Regulation E error resolution procedures.

When a customer disputes a fraudulent transaction, the bank provisionally credits the customer’s account for the amount the customer claims is fraudulent. Following regulatory guidelines, the bank has 10 business days from the date the customer notifies the bank of the allegedly fraudulent transaction to either provisionally credit the customer’s account or issue final credit. Now, let’s suppose the account in question is an interest-bearing account. According to Section 1005.11(c)(2)(i), the provisional or final credit amount should include interest that would have been accrued. In recent years, the low rate environment has rendered any interest earned too small to calculate, even for institutions that wait the full 10 business days to provide credit.
​
However, as interest rates trend upward, institutions need to pay attention to interest calculations for error disputes, especially for large dollar disputes. The intent of the regulation is to make the customer whole after the fraudulent activity has occurred. For customers with interest-bearing accounts, banks must return not only the amount disputed but interest that would have been earned as well.
0 Comments



Leave a Reply.

    Archives

    March 2025
    February 2025
    January 2025
    November 2024
    October 2024
    September 2024
    August 2024
    July 2024
    May 2024
    March 2024
    February 2024
    January 2024
    December 2023
    November 2023
    September 2023
    July 2023
    June 2023
    May 2023
    April 2023
    March 2023
    February 2023
    January 2023
    December 2022
    November 2022
    October 2022
    September 2022
    August 2022
    July 2022
    June 2022
    May 2022
    April 2022
    March 2022
    February 2022
    January 2022
    July 2021
    May 2021
    February 2021
    January 2021
    October 2020
    August 2020
    May 2020
    April 2020
    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    March 2019
    January 2019
    September 2018
    August 2018
    June 2018
    May 2018
    April 2018
    February 2018
    January 2018
    October 2017
    August 2017
    July 2017
    June 2017
    March 2017
    February 2017
    October 2016
    September 2016
    August 2016
    June 2016

    RSS Feed

Proudly powered by Weebly