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:
Banks are required to review documentation or written, signed statements provided by the consumer to ensure a transaction was authorized. Additionally, analyzing historical information on the customer's pattern of use, such as the time, location, and types of transactions, helps in identifying any inconsistencies that could suggest unauthorized activity. These measures are part of the reasonable steps banks must take according to the OCC to determine the legitimacy of a transaction.
The correct answer is B. Historical information on the customer's pattern of use (such as time, location, types of transactions, and so on). The Office of the Comptroller of the Currency (OCC) requires banks to take reasonable steps to determine whether a transaction was authorized, beyond the mere use of a consumer's PIN or ATM card. Analyzing the historical patterns of a customer's transactions can provide valuable insights into whether a particular transaction is consistent with the customer's typical behavior, thereby helping to ascertain its legitimacy. This approach allows banks to more accurately identify unauthorized transactions and protect consumers' accounts.
It is A, B and C, page 636: 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 the 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: i. Documentation or written, signed statements provided by the consumer NOTES ii. Historical information on the customer’s pattern of use (such as time, location, types of transactions, and so on) iii. Location of the transaction in relation to the customer’s home, place of business, and normal shopping locations iv. Customer’s location at the time of the transaction v. Problems reported by other customers regarding the access device or ATM vi. Signature information on POS transactions vii. Police reports viii. Film from security cameras, if available