1026.8 - Identifying Trxns on Statements

Question 1

What must be disclosed/described as a result of credit transactions (sales)

Answer 1

Brief identification of property/services purchased with reasonable precision, the seller’s name, city/state (or foreign country) where trxn took place. May be omitted if trxn took place online, in home, mail or telephone.

Question 2

When do credit transaction descriptions not need to be identified?

Answer 2

In the event that a copy of a sales receipt or other credit document is provided with the first statement including the trxn. Date and amt must also be disclosed.

Question 3

How should installment transactions be identified on statements?

Answer 3

First statement should either disclose entire purchase amount with date of trxn OR the first installment amt with trxn date or date that first installment was debited. Subsequent trxns can show date of each debit or date of initial transaction.

Question 4

Trxn dates based on trxn method

Answer 4

In-person: date of purchase made
On-going not installment: each debit date
Mail/Internet/Tele: Can either be invoice date, debiting date or order date
Foreign: can be debiting or trxn date

Question 5

How to handle multiple dates on stmts

Answer 5

If FI only uses trxn date then it need not identify it as such. However, if it uses more than trxn date, it must label/identify each.

Question 6

What must be disclosed for non-sale credit (cash advance, overdraft advance, check, etc.)

Answer 6

Brief identification, date, amt and date. Date can be trxn date, debit date or date appearing on any signed document.

Question 7

Procedures for FIs that treat stmt clarification as billing error

Answer 7

FI should reasonably look to obtain necessary information, may disclose common number or symbol