Regulation E: Back to Basics Series

For the past three issues of ABA Risk and Compliance magazine, CrossCheck Compliance has contributed its Regulation E: Back to Basics series. These articles offer guidance on the regulation’s most significant requirements, compliance challenges, and enforcement trends.

Remittance Transfers By Elizabeth Crew, CRCM, CAMS Elizabeth Crew examines Regulation E, Subpart B, which governs the global remittance market. She highlights sources of compliance violations and enforcement actions, and provides considerations for disclosure format and timing, error resolution procedures, and proper handling of cancellations and refunds. Read the article
Compliance Management of Overdraft Programs By Jim Treacy Jim Treacy explores regulatory requirements under Section 1005.17(a) related to overdraft practices. He highlights mandatory opt-in procedures for certain transactions, strict disclosure standards, and risks associated with “authorize positive, settle negative” (APSN) transactions, as well as key elements of an effective compliance management system. Read the article
Procedures for Resolving Errors By John Pace, CRCM John Pace breaks down key requirements under Section 1005.11 for error resolution. He offers practical considerations for building an effective resolution program, meeting investigation timelines, and managing provisional credit to stay aligned with regulatory expectations. Read the article

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