The OCC has determined that a national bank may not assume that, simply because a consumer's PIN or ATM card was used in a transaction, that transaction is authorized. Banks are required to take reasonable steps to determine whether the transaction was authorized. Such steps might include the bank's review of:

Question

Quizplus · Accepted Answer

Both choices A and B are reasonable steps for a bank to take in order to determine whether a transaction was authorized. Documentation or written statements provided by the consumer can help confirm that the transaction was authorized, while historical information on the customer's pattern of use can help identify any unusual activity or potential fraud. Choice C, problems reported by regular customers, may be useful in identifying issues with access devices or ATMs, but may not necessarily help in determining whether a specific transaction was authorized. Choice D, legal reports, may be helpful in cases of suspected fraud, but is not a practical step for a bank to take in every transaction.

The OCC Has Determined That a National Bank May Not