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The De Minimus Exemption Of Stored Value Cards From Regulation E: An Invitation To Fraud?, Sean M. O'Connor
The De Minimus Exemption Of Stored Value Cards From Regulation E: An Invitation To Fraud?, Sean M. O'Connor
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How valuable is $100? To a student? To a single unemployed parent? To a well-compensated professional? The Federal Reserve Board apparently believes that the potential loss of $100 is not a tremendous burden on anyone. In a recently proposed rule, the Board exempts stored value cards[that contain less than $100 from the same regulations that protect consumers from most types of fraud associated with ATM, debit, and credit cards. Regulation E (Reg E) currently regulates the electronic funds transfers (EFTs) that are at the heart of ATM/debit/credit card transactions by requiring printed receipts, error resolution procedures, periodic statements, initial disclosure …