3 Debit Cards Flashcards
(a) What is the most important distinction between debit and credit cardholder rights under TILA?
(b) Why? What statute do debit card transactions fall under?
(a) Debit cardholders do not have the same withholding rights as CC holders, also have their own separate unauthorized transaction rights.
(b) EFTA covers debit card transactions.
What are the three relevant time periods to consider when analyzing a debit card transaction problem (and the rules surrounding it)?
EFTA §909
Period 1: From the customer learning of the loss to the first of either notification or two days after learning of the loss.
•CH liability for the amount lost during the period, capped at $50.
Period 2: From two days after the loss till the first of either notification or 60 days following issuance of the first statement including unauthorized charges.
•CH liability for the amount lost, capped at $500 overall. (so if $50 in first period, CH only liable for up to $450 from this period)
Period 3: From 60 days after the first statement including any unauthorized charges is issued to notification.
•CH liability for all amounts lost during this period.
