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Question 205 - CRCM discussion
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:
A.
Documentation or written, signed statements provided by the consumer
B.
Historical information on the customer's pattern of use (such as time, location, types of transactions, and so on)
C.
Problems reported by regular customers regarding the access device or ATM
D.
Legal reports
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