Regulation E: The Changing Face of ANR

This Recipe's Chef

If you have specific questions about this recipe or project, please let us know.

2 chefs for this recipe:
Scott Collins & Jim Vilker.

Updated: August 2nd 2010

Recent Communications

Members Opted In/Out/Undecided
Request Form to Exclude Organizational Accounts from Opt Out Flood; a response is required by August 6
Fee Analysis by Opt In/Out Status
More CEO Thoughts on Regulation E
Reg E Updates Announcement (sent 7/7/10 to all clients)
It's Me 247 Opt In/Opt Out Selection - What a Member Sees
Reg E Updates Announcement (sent 7/6/10 to all clients)
Reg E Discussions from the Leadership Conference
Reg E Opt-in Research (Grand Rapids Financial Institutions)
A CEO's Thinking on Regulation E
CU*BASE Opt In/Opt Out Tools
Misc. Secured Funds for Debit Card Authorizations
Reg. E: What is “Overdraft Service” Email from Randy Karnes (sent 5/11/10 to the CU*Answers and Xtend Boards)
Reg. E: Note to Network CEOs from Jim Vilker and Scott Collins (sent 5/11/10 to all clients)
Answers to frequently-asked questions in the AnswerBook

Reg. E Is Still Cooking!

An update on some new projects just underway:

Reg E. and Your Business Accounts

A few CUs have asked about how they can treat their business accounts differently than the rest of their memberships. There is a form you can use to exempt MO organizational accounts from the August 15 flood (open the flyer; a response is required by August 6). We also have started work on project #28078 which will allow you to set Reg. E exemptions by Membership Designation. (See “Reg. E Projects” below for more details.) In the meantime, once your credit union sets a policy it will be important to educate your staff as to the proper way you wish to treat business memberships.

Opt In Notices

We are also working on programming a notice event for members when they Opt In. Remember that until we can complete this project you must monitor your member activity and generate notices manually (Query file MASTRL or the audit log file AUDTMBRDT).

Canned Queries to Help

To help you analyze the impact of Reg. E on your fee income, we created a canned Query that analyzes Opt In/Out status for members who had fees in 2010 (MNQRY2 #24). We've also added another one to help you to review your entire membership's Opt In/Out status, regardless of fee activity (MNQRY2 #25).

ATM/Debit Vendor Update

During July and August we are continuing to work with the ATM/Debit vendors to implement their changes for flagging debit card transactions as recurring or non-recurring. Some vendors are requiring certification (PEMCO certification is week of July 26; Visa DPS week of August 17), in addition to our own development and QC testing for 10 different vendors. The plan is to tag the transaction descriptions in some way so you can tell which is which (exact method to be determined). In the meantime, all debit card transactions will be treated as everyday transactions (non-recurring).

Reg. E Projects

Project sheets currently in development, with target release dates (contact dmoore@cuanswers.com for a copy of the working specifications):

	Proj#	Description	Target Release
Part 1: Master Controls	27071	Includes new on/off switch in CU Master Parms so CUs can decide whether or not they will use opt in/out functionality at all. Also contains separate on/off switch for displaying the flags in It’s Me 247.	Implemented 10.1
Part 2: Posting	27071	Includes changes to the ATM/Debit posting programs to obey the new flags (can be released after maintenance programs are in place). (Supported ONLY for CUs that have converted to the new Standard ATM/Debit Card Platform)	Implemented in July
Part 3: Setting Mbr Flags in CU*BASE	27071	Includes maintenance of flags, inquiry, and writing to a special new audit log file	Implemented 10.1
Part 4: Setting Mbr Flags in It’s Me 247	27336	Maintenance of flags and writing to a special new audit log file	Implemented in July
Part 5: Notices	27337	Creating Notice Event whenever flags are changed (see parts 2 and 3)	10.3
Part 6: File Maintenance Analysis Tools	TBD	Possible future tools to analyze the data being written to log file showing opt in/out status (will use Query in the meantime)	Ongoing
Part 7: Reg E Opt In/Out Controls by Membership Designation	28078	Adds a new control flag so CUs can deactivate Reg E Opt In/Out functionality for specific Membership Designation codes (business accounts). Simply hides the fields from displaying in CU*BASE and It's Me 247 (recorded as opted IN behind the scenes in the database).	10.4 (tentative)

A Message from Xtend: Getting Ahead of Reg. E

(As sent 2/12/2010 via email from Scott Collins, President of Xtend, Inc.)

Over the past several weeks, it has been interesting to watch the marketplace react to the new Reg. E revision affecting many of our credit unions’ ANR programs. As anticipated, the first to react were the consultants, armed with proposals to help you protect your revenue stream by moving quickly to get members to Opt In based on the legislation. Marketing companies were quick to react as well, offering a variety of solutions for a pre-emptive strike on the Opt In opportunity. And calls began to trickle in to both CU*Answers and Xtend for commentary. The bottom line message from Grand Rapids is DO NOT PANIC… Some important information:

We are crafting a solution that leverages our collective CUSO resources. It is our intent to begin the execution phase in April/May, well in advance of the August 15th ATM/Debit card “shut off” date. This should also limit the risk of having members Opt Out between now and then by pulling the trigger on a program too early. Highlights of our proposed service will be covered below.

An informational Web Conference on Tuesday, May 18th at 2:00 pm ET will discuss these solutions in more detail.
CU*BASE – specification work is already in process (1 byte field to distinguish between one-time and recurring debit transactions based on new ISO field delivered by switches; Opt In identifier with time stamp and EmpID/channel; event creation for notice generation; possible integration with online banking; etc.). These will likely be phased in throughout the next several CU*BASE releases – updates will be delivered via The Kitchen on our website.
Xtend Service – it is our intent to deliver an effective Opt In support solution at an affordable price point. We will enlist partners like CU*Answers on the tool side and Sage on the mailing execution side. Our vision of the solution includes:

Task	Xtend Service	Self Service
Form letter with unique identifier per member	Included in fee	CU can use as appropriate
Query to determine targeted members	Included in fee	Placed in CU library
Mailing to selected members	Included in fee	Vendor info supplied to CU as needed
One time Email and Online Banking Message	Included in fee	Messages placed in CU*BASE master library; delivery by CU
Staff talking points	Included in fee	CU can use as appropriate
Opt In report generated by web application	CU*BASE update handled by Xtend	CU*BASE update handled by CU
Member confirmation	Included in fee	Handled by CU
Outbound member calls (after mailing)	Additional fee	Additional fee
Inbound hotline to handle Opt Ins	Additional fee	Additional fee

As you can see there is a lot of work yet to be defined and completed, and along with you we will continue to monitor the regulatory activity as the date gets closer. A broadcast will be sent once a Web Conference date is set. Pricing for the Xtend service will also be forthcoming. As always, we look forward to your input as we craft our solution together.

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