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:
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A. B. C. D.AB
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The OCC (Office of the Comptroller of the Currency) is a US federal agency that regulates and supervises national banks and federal savings associations. As per the question, the OCC has determined that national banks must take reasonable steps to determine whether a transaction made using a consumer's PIN or ATM card was authorized, instead of assuming that it was authorized solely based on the use of the PIN or card.
The options presented as possible steps that the bank could take to determine whether a transaction was authorized are as follows:
A. Documentation or written, signed statements provided by the consumer: One possible step that the bank could take is to request documentation or written, signed statements from the consumer indicating whether or not the transaction was authorized. This could help the bank establish whether the transaction was authorized by the consumer or not. For example, the bank may ask the consumer to provide a signed statement indicating that they did not authorize the transaction in question.
B. Historical information on the customer's pattern of use (such as time, location, types of transactions, and so on): Another possible step that the bank could take is to review historical information on the customer's pattern of use, which could include details such as the time, location, and types of transactions that the customer typically makes. This information could help the bank establish whether the transaction was consistent with the customer's usual pattern of behavior or not. For example, if a transaction was made at an unusual time or location, or for an atypical amount, it may be more likely that the transaction was not authorized by the consumer.
C. Problems reported by regular customers regarding the access device or ATM: A further step that the bank could take is to review any problems that regular customers have reported regarding the access device or ATM that was used to make the transaction in question. This could help the bank identify whether there were any issues with the device or ATM that could have resulted in unauthorized transactions. For example, if other customers have reported issues with the same ATM, it may be more likely that the transaction was unauthorized.
D. Legal reports: Finally, the bank could also review any legal reports that may be relevant to the transaction in question. This could include reports of fraud or other criminal activity that could have affected the transaction. For example, if there have been reports of a particular type of fraud in the area where the transaction was made, it may be more likely that the transaction was unauthorized.
In summary, the OCC requires that national banks take reasonable steps to determine whether a transaction made using a consumer's PIN or ATM card was authorized, and the options presented in the question outline some possible steps that banks could take to meet this requirement. These steps include reviewing documentation or statements from the consumer, reviewing historical information on the customer's pattern of use, reviewing problems reported by regular customers, and reviewing legal reports.