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Washington
Compliance The dog ate my ATM receipt
WASHINGTON (1/28/08)—The Federal Reserve Board’s Regulation E, governing electronic funds transfers, requires that a receipt be made available for each transaction at an electronic terminal, unless the consumer declines the receipt. So, what happens when there is an honest mistake? While it’s clear the “dog ate my receipt” excuse doesn’t quite fit the situation, the “dog ate my ATM’s receipt paper roll” might. The Credit Union National Association’s January Compliance Challenge asks, would a credit union have violated the Reg E requirement if its ATM runs out of paper and fails to give someone a receipt? And the answer is no. Comment 205.9(a)(5) in the regulation clarifies that if a receipt is not provided to the consumer because of a bona fide unintentional error, such as when a terminal runs out of paper, or the mechanism jams, no violation results if the financial institution maintains procedures reasonably adapted to avoid such occurrences. So, having procedures in place to prevent this from happening on a routine basis is the key to avoiding a Regulation E violation in these instances, the Challenge advises.


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