TAG

Payments compliance

Error resolution, network rules, and money movement duties.

FIN-01 · 01

Regulation E Error Resolution for Digital Wallets and Payment Applications

7 MIN · FIN

Regulation E turns a consumer complaint into a regulated clock. This brief sets out when the clock starts, which investigation window applies, when provisional credit becomes mandatory, and what must be sent in writing.

A consumer has 60 days from the periodic statement showing the problem to assert an error; late notice generally ends the institution's resolution duty.
The default investigation window is 10 business days, extendable to 45 calendar days only if provisional credit is given and the consumer notified.
New accounts, point-of-sale debit transactions, and foreign-initiated transfers use longer windows — 20 business days and 90 calendar days.

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FIN-04 · 02

ACH Authorization, Returns, and Account-Freezing Risk for Payment Platforms

9 MIN · FIN

A debit can be contractually agreed, network-compliant, and still returned. This brief separates the three rulebooks that govern ACH authorization, returns, and funds holds for a platform operator.

Nacha rules make the originating bank warrant that each entry is authorized, and require proof of authorization to be retained and produced on request.
Retention for consumer debit authorizations generally runs two years from the date the authorization is terminated or revoked.
Return-rate levels are measured against the originator: 0.5% unauthorized, 3% administrative, and 15% overall, each triggering network review.

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FIN-07 · 03

Custodial and FBO Account Structures: Whose Money Is It

8 MIN · FIN

An FBO account holds one balance at a bank and many claims outside it. This brief separates legal ownership from operational control, and sets out the titling, records, and disclosure conditions the structure depends on.

An FBO account is a single deposit at a bank held by an intermediary for identified end users, whose individual claims exist only in the intermediary's ledger.
Pass-through insurance conditions include custodial titling, records identifying the true owners and their interests, and a genuine disclosed agency relationship.
The label 'FBO' on an account title creates nothing by itself; the underlying agreements and state law determine whether a trust or agency actually exists.

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