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Request For Comment

  • 18-04-2012 4:56pm
    #1
    Registered Users, Registered Users 2 Posts: 7,265 ✭✭✭


    Bank of Ireland representatives. In your official capacity, can you comment on the following items relating to the Direct Debit Scheme? I understand that you may not have immediate answers.

    1. How much training does Bank of Ireland staff receive, specifically related to Direct Debit Scheme? Is it on a group or branch level?
    2. Why is it so difficult to get bank staff to follow the Direct Debit Scheme rules?
    3. If one cancels a direct debit with their branch, can, after two months, an Originator re-activate that mandate in ANY way?
    4. Why, apparently, can an unknown entity setup a direct debit mandate with an originator, and the PAYER bank actually pay out the money knowing that the unknown entity is not a signatory on the account?
    5. Why, apparently, if I cancel a direct debit with my branch AND close my account fully AND open a totally new account with absolutely NO direct debits, will the bank honour a direct debit on the old account and chase me for recompense?
    6. Under what circumstances does Bank of Ireland report fraud and to what bodies?

    I await your comments.


Comments

  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    I would also be interested to know in your role as a sponsoring bank what checks are carried out on a company requesting sponsorship in the dd scheme.

    When a sponsorship is agreed what subsequent checks are are carried out to ensure that the company concerned is complying with the dd scheme rules.

    Who is responsible in a branch overall for overseeing the sponsorship process.

    There is supposedly a committee which as a role in monitoring the operations of the dd scheme. Given that no one in BOI apparently has a clue as to how the dd scheme operates what arrangements are in place to keep BOI's representative up to date on problems which branches encounter with the dd system?

    Given that the so called dd guarantee states:


    A Direct Debit Guarantee is provided by your bank in the following form:

    If you authorise payment by direct debit, then
    Your direct debit originator will notify you in advance of the amounts to be debited to your account

    What process has BOI in place to ensure that originators will provide the correct advance notice to bill payers?

    The dd guarantee also states
    You can cancel the Direct Debit Instruction by writing in good time to your bank

    Isn't it the case that this statement is in fact a lie and that a direct debit instruction cannot be cancelled with any assurance of finality?
    Paying Banks:
    o must adhere to the Rules of the Scheme
    o must put in place processes which will ensure that unauthorised, refused and/or cancelled
    Direct Debits are intercepted and returned immediately on presentation
    o must promptly present indemnity claims arising under or pursuant to the Scheme
    o must assist its customer, to the extent practicable, in the resolution of disputes arising under or
    pursuant to the Scheme
    o must inform the Sponsoring Bank if an Originator is not adhering to the Rules of the Scheme

    Above is the list of obligations of paying banks under the dd scheme rules.

    How do BOI consider that they comply with the points therein particularly no 2?

    Also given that staff appear to have no idea how the scheme works or their obligations under it how do BOI comply with point no 4 above?


  • Closed Accounts Posts: 5,668 ✭✭✭nlgbbbblth


    Point 5 = untrue.


  • Registered Users, Registered Users 2 Posts: 9,222 ✭✭✭Tow


    nlgbbbblth wrote: »
    Point 5 = untrue.

    It is true for debits from credit cards.

    The biggest problem with all the above is no way of putting a permanent block on an originator number from DDing your account. The rest are ongoing basic staff training issues, to which I could add a few more...

    There DD scheme is based on honor and trust, as is (was) the whole banking system.

    When is the money (including lost growth) Michael Noonan took in the Pension Levy going to be paid back?



  • Registered Users, Registered Users 2 Posts: 5,578 ✭✭✭Slutmonkey57b


    Tow wrote: »
    It is true for debits from credit cards.

    The biggest problem with all the above is no way of putting a permanent block on an originator number from DDing your account. The rest are ongoing basic staff training issues, to which I could add a few more...

    There DD scheme is based on honor and trust, as is (was) the whole banking system.

    Direct Debit != Debit Card transaction, afaik.


  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    Direct Debit != Debit Card transaction, afaik.

    Totally wrong. Nothing to do with each other whatsoever!


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  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Hi all,

    Thanks for your queries and our best efforts are being made to answer them as soon as possible. Due to the number of questions, it may take some time for us to gather the information. We'll respond as we get the facts and refer back to the relevant post to make it clear which question we're answering.

    Thank you all for your patience in this regard,
    Graham


  • Registered Users, Registered Users 2 Posts: 5,578 ✭✭✭Slutmonkey57b


    dub45 wrote: »
    Totally wrong. Nothing to do with each other whatsoever!

    != means "does not equal" in some computer programming languages.


  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    dub45 wrote: »
    Totally wrong. Nothing to do with each other whatsoever!

    != means "does not equal" in some computer programming languages.

    Given that the thread is not restricted to programmers could you post in plain English for the rest of us?


  • Registered Users, Registered Users 2 Posts: 5,578 ✭✭✭Slutmonkey57b


    Could do, but I'd be breaking a long standing tradition on boards. I promised my granny I'd keep up the old ways etc.


  • Closed Accounts Posts: 5,668 ✭✭✭nlgbbbblth


    Tow wrote: »
    It is true for debits from credit cards.

    Yes. But you'd want to be insane to set up a direct debit on a credit card account.


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  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Apologies for the delay in returning to your queries. Your posts are important to us and we'll be in touch early next week with an update.

    Hope you all have a good weekend.

    Thanks,
    Graham


  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Hi RangeR,

    We hope that you find the below satisfactory.
    RangeR wrote: »
    1. How much training does Bank of Ireland staff receive, specifically related to Direct Debit Scheme? Is it on a group or branch level?

    2. Why is it so difficult to get bank staff to follow the Direct Debit Scheme rules?

    The level of training that staff receive in relation to the Direct Debit Scheme would relate to the area of the bank that they work in and the activity they carry out. Unfortunately we can't provide detailed information about our specific training programme. If you're in touch with us and we can't supply you with sufficient information at that time, we'll always be happy to find out more and contact you back regarding the query you have.
    RangeR wrote: »
    6. Under what circumstances does Bank of Ireland report fraud and to what bodies?

    In most instances we request that customers report incidents of fraud to the Gardaí as they are the intended victim of the crime. We'll also investigate any instances of fraud that are brought to our attention to the fullest extent. We'll then liaise and assist Gardaí in any way we can with their enquiries. In order to protect the security and privacy of our customers' accounts we can't comment any further on any of our security or fraud procedures.

    We hope to have more information on your other queries shortly.

    Thanks,
    Graham


  • Registered Users, Registered Users 2 Posts: 7,265 ✭✭✭RangeR


    The level of training that staff receive in relation to the Direct Debit Scheme would relate to the area of the bank that they work in and the activity they carry out. Unfortunately we can't provide detailed information about our specific training programme. If you're in touch with us and we can't supply you with sufficient information at that time, we'll always be happy to find out more and contact you back regarding the query you have.

    Fair enough on the reporting to Gardaí. However, under the Direct Debit Scheme rules, guarantees and processes, it is incumbent on a persons local branch to assist in Direct Debit issues.

    In ALL instances, with branches Smithfield, Bray and Naas, EVERY person that I spoke to had no idea on how the Direct Debit scheme worked. Even in it's simplest form.

    Every time, I was fobbed off and told to speak to the originator rather than the bank getting involved. This is plain wrong. And I'm not speaking of an isolated incident. It's been multiple times over the space of just a few months.

    It appears, to the Average Joe, that there is apparently NO training provided to the front line staff. The same staff that field phone calls from customers with Direct Debit issues.

    And it wasn't just front line staff I was speaking to. I was speaking to members of staff from various departments and rank [not including actual branch manager]. NOBODY seemed to know how the Scheme operates.

    In fact, IPSO provide training material to ALL banks to assist in this training.

    There are only three reasons that I can think of, as to why this is the case.

    1. Training is not provided
    2. Staff are trained but they all forget.
    3. It's bank policy to make it as difficult as possible for customers to get THEIR money back, as there is a window where the bank is actually liable for the loss.


    I would put it to you that your training program has failed, in this regard.


  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Hi dub45,

    Apologies for the delay in responding to you, it has taken a bit time to get the information together. Here are the answers to your queries and I'll follow up with more information as soon as I get it.
    dub45 wrote: »
    I would also be interested to know in your role as a sponsoring bank what checks are carried out on a company requesting sponsorship in the dd scheme.

    There are a range of checks done in order to satisfy us as a sponsoring bank that a new direct debit originator can fulfil the obligations of the DD Scheme. These include, but are not limited to, the relationship between the potential originator and us, and the purpose/use of the direct debits set up by them. If a company can't meet the criteria we set out and sponsorship isn't granted then we cannot proceed to set up the company as a direct debit originator. A new originator must also meet all requirements of IPSO.
    dub45 wrote: »
    When a sponsorship is agreed what subsequent checks are are carried out to ensure that the company concerned is complying with the dd scheme rules.

    As part of the set up of a new direct debit originator, there are a number of items that are checked to ensure that the prospective originator is scheme compliant. We provide the applicant with the scheme rules and work with them to ensure they have a detailed understanding of those rules. Once they are up and running we retain the ability to monitor and/or audit their processes if we see fit. In the majority of cases originators adhere to scheme rules. However, in cases where a series of complaints have been received from payers (account holders permitting DD's), we may seek to investigate this which may result in a review of the originator's processes to ensure scheme compliance.
    dub45 wrote: »
    Who is responsible in a branch overall for overseeing the sponsorship process.

    The potential originator's business advisor or relationship manager oversees originator sponsorship. A regional business manager may also be involved in considering prospective direct debit originators.
    dub45 wrote: »
    There is supposedly a committee which as a role in monitoring the operations of the dd scheme. Given that no one in BOI apparently has a clue as to how the dd scheme operates what arrangements are in place to keep BOI's representative up to date on problems which branches encounter with the dd system?

    I am still looking into the processes we have in place for escalating issues with direct debits to our representative. I will return on this when I have more information.
    dub45 wrote: »
    What process has BOI in place to ensure that originators will provide the correct advance notice to bill payers?

    The rules of the Direct Debit Scheme, which are fully explained to all new originators, highlight the requirements for advance notice of debits. Once a new originator has registered for the scheme, they have signed up to abide by its rules and regulations. In the event of a payer complaint about receiving insufficient or no notice period we would contact that originator to investigate. Continuous breaches may result in sponsorship being removed.
    dub45 wrote: »
    Isn't it the case that this statement is in fact a lie and that a direct debit instruction cannot be cancelled with any assurance of finality?

    In the vast majority of cases when a direct debit is cancelled by a customer, the originator is advised and the direct debit never occurs again. However, to cater for the potential for the customer and the originator to become payer/payee at some future stage, it is possible for a direct debit to re-occur at a future date. This can only be done with authorisation from the customer and if it is an error the customer will always have recourse through the direct debit guarantee.
    dub45 wrote: »
    How do BOI consider that they comply with the points therein particularly no 2?

    We comply with the scheme rules and work closely with IPSO to ensure this is maintained. The scheme has a number of different methods for the submission of direct debits which may or may not result in paper transmission of mandates. In the case of paper mandates, these are checked for accuracy and appropriateness. In relation to customers requesting cancellations, refusals etc., this is managed on request from the customer. In the occurence of errors with the operation of a direct debit, the customer is protected by the Direct Debit Guarantee and will be refunded any unauthorised, refused or cancelled DD's that are incorrectly processed.
    dub45 wrote: »
    Also given that staff appear to have no idea how the scheme works or their obligations under it how do BOI comply with point no 4 above?

    The DD Scheme can be quite complex so it's possible that some staff who don't deal with it regularly may not be as knowledgeable on the topic as others. However, to improve both customer and staff understanding of the scheme we're working with IPSO to develop tools/guides for staff with information on the key DD Scheme features.

    I hope this helps to address some your concerns and I'll return with more information on your other query when I have it.

    Thanks,
    Graham


  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Hi RangeR,

    I've just heard back with some more information on your other queries:
    RangeR wrote: »
    3. If one cancels a direct debit with their branch, can, after two months, an Originator re-activate that mandate in ANY way?

    If a customer cancels a direct debit mandate with us, an automated letter is issued to the originator that evening. The originator should at that point cancel the mandate on their system and not attempt to debit the account again. We hold cancelled instructions on our system for 2 months, so it's possible for an originator to resubmit a direct debit payment to a previously closed mandate after that time, this typically only happens on the agreement with the customer. If the direct debit is submitted in error the payment would be refunded under the Direct Debit Guarantee and the originator would be advised.
    RangeR wrote: »
    4. Why, apparently, can an unknown entity setup a direct debit mandate with an originator, and the PAYER bank actually pay out the money knowing that the unknown entity is not a signatory on the account?

    A non-signatory shouldn't be able to set up a direct debit instruction on an account which isn't theirs. However, if the originator is a Direct Debit Plus Originator they can take an instruction from the customer over the phone to debit an account. They are advised to get the relevant documentation from the customer. In these circumstances we are not provided with a copy of a paper mandate. The customer's account would again be refunded under the Direct Debit Guarantee and the originator would be advised of the error.
    RangeR wrote: »
    5. Why, apparently, if I cancel a direct debit with my branch AND close my account fully AND open a totally new account with absolutely NO direct debits, will the bank honour a direct debit on the old account and chase me for recompense?

    If an account is fully closed direct debits cannot and will not be allowed. The debits will reject back to the originator as "Account Closed". However, if the account has been closed at branch level and the branch have put a "Forward" indicator on the account, all debits will be passed onto the new account. This is typically for account switching.

    If you need any more information or have any other questions please don't hesitate to ask.

    Thanks,
    Graham


  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    Hi RangeR,

    I've just heard back with some more information on your other queries:


    A non-signatory shouldn't be able to set up a direct debit instruction on an account which isn't theirs. However, if the originator is a Direct Debit Plus Originator they can take an instruction from the customer over the phone to debit an account. They are advised to get the relevant documentation from the customer. In these circumstances we are not provided with a copy of a paper mandate. The customer's account would again be refunded under the Direct Debit Guarantee and the originator would be advised of the error.

    Error? How is it that when a company takes money from a customer's account without permission it is always an "error"?

    This is one of the many things that baffles me about the acceptability of the so called direct debit plus system.

    How can it it be acceptable for a bank to allow access to a customer's account without holding any documentation whatsover for the transaction?

    How can the integrity of a customer's account be maintained when accounts are wide open to such access? Is the system acceptable to your internal auditors (or whoever the appropriate authority is)? Has such a system being passed as meeting all the bank's requirements? how can any customer have confidence in a banking system which allows access to a customers accounts without appropriate documentation being in place?

    Also I have a pain in my proverbial reading that in the event of an "error" the customers account would be refunded. This attitude by the banks and IPSO is completely unacceptable - i.e. that everything a company does is ok because it can be fixed up afterwards irrespective of the inconvenience and cost to the customer.

    It effectively means that accounts are not protected and companies can and do what they like without any fear of sanction. It takes no account whatsoever of the potential to wreak havoc on a customers account (whereas as I continually point out if a customer misses a dd payment he or she is instantly punished with hefty charges).

    Meteor took 800 euros from an account without any problem whatsoever. And nothing will happen to them. If I took a fiver off the counter in a bank and told them they could have it back tomorrow I would be getting hauled off in a garda car.

    It is instructive that apparently it took the intervention of Comreg for Meteor to actually respond to Ranger in this case. So much for the "fear" of the bank or IPSO.


  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    RangeR wrote: »
    Fair enough on the reporting to Gardaí. However, under the Direct Debit Scheme rules, guarantees and processes, it is incumbent on a persons local branch to assist in Direct Debit issues.

    In ALL instances, with branches Smithfield, Bray and Naas, EVERY person that I spoke to had no idea on how the Direct Debit scheme worked. Even in it's simplest form.

    Every time, I was fobbed off and told to speak to the originator rather than the bank getting involved. This is plain wrong. And I'm not speaking of an isolated incident. It's been multiple times over the space of just a few months.

    It appears, to the Average Joe, that there is apparently NO training provided to the front line staff. The same staff that field phone calls from customers with Direct Debit issues.

    And it wasn't just front line staff I was speaking to. I was speaking to members of staff from various departments and rank [not including actual branch manager]. NOBODY seemed to know how the Scheme operates.

    In fact, IPSO provide training material to ALL banks to assist in this training.

    There are only three reasons that I can think of, as to why this is the case.

    1. Training is not provided
    2. Staff are trained but they all forget.
    3. It's bank policy to make it as difficult as possible for customers to get THEIR money back, as there is a window where the bank is actually liable for the loss.


    I would put it to you that your training program has failed, in this regard.

    Could I add to the above and ask why is there no booklet available in bank branches (and this does not just apply to BOI) which would explain the workings of the dd scheme and their entitlements under it to customers?

    This would obviously be a good help in the demonstrable absence of appropriate training for staff. Many bank staff do not even appear to know of the existence of IPSO let alone the consumer pages on their website.

    Given that the scheme was introduced in 1967 surely everyone involved has had more than enough time to produce one? The lack of such a basic aid is a disgrace given that the banks appear to have no problem in spending lots of money on all sorts of glossy brochures.


  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    Hi dub45,

    Apologies for the delay in responding to you, it has taken a bit time to get the information together. Here are the answers to your queries and I'll follow up with more information as soon as I get it.
    ...............................


    ............I hope this helps to address some your concerns and I'll return with more information on your other query when I have it.

    Thanks,
    Graham

    Firstly I would like to say thanks for responding so quickly and indeed undertaking to respond at all and I would also like to thank you for the breadth of your response although sadly I cannot thank you for the depth of your response as unfortunately it is long in aspiration and smacks all to readily of the dead hand of PR.

    There are a range of checks done in order to satisfy us as a sponsoring bank that a new direct debit originator can fulfil the obligations of the DD Scheme. These include, but are not limited to, the relationship between the potential originator and us, and the purpose/use of the direct debits set up by them. If a company can't meet the criteria we set out and sponsorship isn't granted then we cannot proceed to set up the company as a direct debit originator. A new originator must also meet all requirements of IPSO.

    I asked you what checks are carried out but you still haven't told me?

    What has the relationship with yourselves got to do with it? What exactly does that prove?

    The purpose/use of the dd? Seriously? What the hell does BOI think the purpose of a dd is?

    So can I ask you again what checks are carried out on a prospective member of the dd scheme?

    And can I remind you that you are talking about businesses that have wide open access to customers accounts so customers should have in depth information on what checks are carried out to allow such wide open access.

    In response to my query - When a sponsorship is agreed what subsequent checks are are carried out to ensure that the company concerned is complying with the dd scheme rules. You state:
    As part of the set up of a new direct debit originator, there are a number of items that are checked to ensure that the prospective originator is scheme compliant. We provide the applicant with the scheme rules and work with them to ensure they have a detailed understanding of those rules. Once they are up and running we retain the ability to monitor and/or audit their processes if we see fit. In the majority of cases originators adhere to scheme rules. However, in cases where a series of complaints have been received from payers (account holders permitting DD's), we may seek to investigate this which may result in a review of the originator's processes to ensure scheme compliance.

    So in other words you don't do anything? You "retain the ability" "If we see fit" " "we may seek" all nice pious PR talk but no regular actual checking procedures in place?

    Also in the absence of any semblance of a proper complaints procedure how would the bank even be aware of complaints about an errant company?

    As has been pointed our already many staff haven't a clue about the workings of the scheme so they are most unlikely to pass on complaints about an errant company so how are the complaints collated which would justify an "Investigation of the originator's compliance'? Who would receive them centrally so as to know there was a problem?

    You say you work with the company to ensure that they have a detailed knowledge of the scheme rules? Forgive my skepticism but given the absence of any such knowledge amongst the majority of bank staff but who does this "working" and what exactly does it involve?
    The potential originator's business advisor or relationship manager oversees originator sponsorship. A regional business manager may also be involved in considering prospective direct debit originators.

    Doesn't your reply here really highlight the reality of the dd scheme and one its inherent weaknesses? The bank and the applying business have a commercial relationship with the bill payer a very poor third. Commercial considerations are going to have a very big influence in any such consideration and also in considering any compliance issues on the part of the business?
    The rules of the Direct Debit Scheme, which are fully explained to all new originators, highlight the requirements for advance notice of debits. Once a new originator has registered for the scheme, they have signed up to abide by its rules and regulations. In the event of a payer complaint about receiving insufficient or no notice period we would contact that originator to investigate. Continuous breaches may result in sponsorship being removed.

    I know very well that the rules of the scheme highlight the requirements for advance notice. In fact the Direct Guarantee which you as a bank give customers states that
    A Direct Debit Guarantee is provided by your bank in the following form:
    If you authorise payment by direct debit, then
    Your direct debit originator will notify you in advance of the amounts to be debited to your account

    We are not talking aspirational stuff here. A guarantee is at the very least a "very strong assurance" or "pledge" or "to make sure of" to just quote some random definitions. The guarantee in respect of advance notice is given by the Bank!

    So to meet the Bank's commitment under the dd guarantee to your customer you explain the rules to the business concerned? Nothing else happens?

    Isn't the reality that this is a guarantee that cannot be kept? It is unworkable even with the best intentions of all concerned. So why does BOI participate in giving an unworkable guarantee which effectively misleads customers?
    In the vast majority of cases when a direct debit is cancelled by a customer, the originator is advised and the direct debit never occurs again. However, to cater for the potential for the customer and the originator to become payer/payee at some future stage, it is possible for a direct debit to re-occur at a future date. This can only be done with authorisation from the customer and if it is an error the customer will always have recourse through the direct debit guarantee.

    I am extremely disappointed in this response as you are apparently avoiding my question. I specifically asked that wasn't if a fact that a direct debit instruction cannot be cancelled with any degree of finality? And you have not answered my question.

    Are you really saying that a direct debit which has been cancelled can only be submitted with the customer's consent? Because if you are this is factually incorrect. You acknowledge this in your reply to Ranger elsewhere.

    So can I once again put it to you. The Direct Debit guarantee states
    You can cancel the Direct Debit Instruction by writing in good time to your bank

    Isn't the reality that a direct debit can never be cancelled with finality. And that once again a key part of the DD guarantee cannot be effected and that the customer is deliberately mislead?

    And please don't say that a cancelled dd can only be resubmitted with the permission of the customer that is not the case. And also a cancelled dd cannot be submitted in "error" certain actions have to be taken by the originator which means any submission of a cancelled dd is deliberate.
    We comply with the scheme rules and work closely with IPSO to ensure this is maintained. The scheme has a number of different methods for the submission of direct debits which may or may not result in paper transmission of mandates. In the case of paper mandates, these are checked for accuracy and appropriateness. In relation to customers requesting cancellations, refusals etc., this is managed on request from the customer. In the occurence of errors with the operation of a direct debit, the customer is protected by the Direct Debit Guarantee and will be refunded any unauthorised, refused or cancelled DD's that are incorrectly processed.

    You say you work closely with IPSO but again what exactly does this mean? Staff are not trained properly there is no information readily available in staff for branches. You say that the customer is protected by the Direct Debit guarantee but in reality the dd guarantee is worthless and effectively a deception of the customer. The notice part is unworkable - dds cannot be cancelled with finality and a customer is entitled to get back what shouldn't have been taken in the first place so where exactly are the benefits of this so called guarantee.

    The facts are that once a customer signs a dd mandate their account is wide open and the banks and IPSO seem to think that everything is ok because it can all be fixed up afterwards -eventually and maybe - with no consideration of the impact of the customer of all these so called "errors"
    The DD Scheme can be quite complex so it's possible that some staff who don't deal with it regularly may not be as knowledgeable on the topic as others. However, to improve both customer and staff understanding of the scheme we're working with IPSO to develop tools/guides for staff with information on the key DD Scheme features.

    Please grant us some intelligence? Complex? This is a scheme which has been in place since 1967 (IPSO have been in place since 1997) - there is no excuse for the level of ignorance amongst bank staff (and not just BOI) about a scheme which affects so many customers. How hard is it for bank staff to be familiar with the basics listed here:

    http://www.ipso.ie/section/section/YourRightsasaPayer

    Again I have a pain in my proverbial reading about this "working with IPSO" what exactly does it mean? When will we see results?

    How hard would it be to produce a simple booklet giving the basics?

    Could I further ask you how is the notice period for the direct debit scheme agreed?

    For example is Bank of Ireland satisfied that the default 7 day notice period in the dd+ scheme is adequate to protect the customers interests? (Given that in effect it allows the customer no time to question a bill they are not satisfied with - two days in any seven will be lost due to a weekend and a further three days are lost due to the transmission of billing data to the bank).

    Also does the Bank take any interest in data protection issues either when considering sponsorship issues or day to day operational issues of its customers.


  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Hi dub45,

    Thanks for your feedback. It is our intention to answer as many queries as we can within this forum, as we take all comments and questions seriously.

    I've been liaising with various departments within the bank to obtain as much of the information requested by both yourself and RangeR as I can.
    However, at present I'm unable to give you any further information within this forum regarding the DD Scheme and our participation in it.
    As detailed in my earlier answer, we always comply with the scheme rules and work very closely with IPSO to make sure that it is thoroughly maintained.

    We've taken on board the feedback throughout in relation to inconsistencies in information received to date and your comments about potential training and branch literature. I've passed these on to my team manager who will in turn forward them on to the relevant people within the bank for further exploration.

    Your subsequent questions relate to more detailed process information that we are unfortunately unable to address in this forum. As per our Forum Charter we're here to offer support with customer service queries on their day-to-day banking and product information. However, if you wish to pursue your line of enquiry further, please PM me your name and number and I'd be happy to arrange a call for you with our direct debit team who will be able to talk through your queries in more detail.

    I'm sorry that we can't offer you more information at this time, but if you do have a question or problem regarding a specific direct debit on any of your Bank of Ireland accounts please feel free to get in touch and we'll be happy to help.

    Thanks,
    Graham


  • Registered Users, Registered Users 2 Posts: 1,529 ✭✭✭zynaps


    We hold cancelled instructions on our system for 2 months, so it's possible for an originator to resubmit a direct debit payment to a previously closed mandate after that time, this typically only happens on the agreement with the customer. If the direct debit is submitted in error the payment would be refunded under the Direct Debit Guarantee and the originator would be advised.
    And how long would it take for a refund to be issued under the DD guarantee? What would be the minimum, maximum and average length of time before the money wrongly taken from the customer is returned?

    I noticed in another thread that someone was told to fill in a form at the branch and wait for 10 days to be refunded... was this a miscommunication?


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  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    Hi zynaps,

    Thanks for your question. The length of time a refund takes can depend on the specific nature of the refund. We expect most of them to be resolved immediately. However, there are circumstances where more information is required and this may take an extra few days for the customer to provide it to us.

    Any forms that need to be filled out are for our own processing and we'll use them in our communication with the Originator in question.

    I'm sorry I can't be any more detailed but I hope this helps.

    Thanks,
    Graham


  • Registered Users, Registered Users 2 Posts: 7,265 ✭✭✭RangeR


    Hi zynaps,

    Thanks for your question. The length of time a refund takes can depend on the specific nature of the refund. We expect most of them to be resolved immediately. However, there are circumstances where more information is required and this may take an extra few days for the customer to provide it to us.

    Any forms that need to be filled out are for our own processing and we'll use them in our communication with the Originator in question.

    I'm sorry I can't be any more detailed but I hope this helps.

    Thanks,
    Graham

    Graham,

    You claim that BOI are compliant with the Direct Debit Scheme. To be compliant, refunds should be IMMEDIATE. THEN the investigation starts.

    There is no grey area here. IPSO are clear on this.


  • Registered Users, Registered Users 2 Posts: 1,529 ✭✭✭zynaps


    RangeR wrote: »
    Graham,

    You claim that BOI are compliant with the Direct Debit Scheme. To be compliant, refunds should be IMMEDIATE. THEN the investigation starts.

    There is no grey area here. IPSO are clear on this.
    I'd have to agree, the rules of the DD scheme seem unambiguous in this regard.

    Graham, I appreciate your taking time to answer some of these questions.
    However, might I suggest that you try to clarify this with the department responsible in your bank? It seems that they are unaware of some of their obligations under the scheme.


  • Closed Accounts Posts: 371 ✭✭Bank of Ireland: Graham


    RangeR and zynaps,

    As I said above, we expect the majority of refunds to be immediate. There are situations where this is not possible. As a paying bank our obligation to a payer is to provide a prompt refund once it has been established that the direct debit was unauthorised. We're responsible for determining that the claim for a refund is genuine, which may require further investigation and/or more information from the customer.

    Thanks,
    Graham


  • Registered Users, Registered Users 2 Posts: 7,265 ✭✭✭RangeR


    RangeR and zynaps,

    As I said above, we expect the majority of refunds to be immediate. There are situations where this is not possible. As a paying bank our obligation to a payer is to provide a prompt refund once it has been established that the direct debit was unauthorised. We're responsible for determining that the claim for a refund is genuine, which may require further investigation and/or more information from the customer.

    Thanks,
    Graham

    ...
    Paying Banks Must:

    Only pay direct debits in accordance with customers’ Instructions
    Ensure that unauthorised and/or cancelled direct debits are intercepted and returned immediately on presentation
    Promptly refund customers for indemnity claims and present the Indemnity to the Originator
    Assist customers in resolving disputes with Originators
    Inform the Sponsoring Bank if an Originator is not adhering to the Scheme Rules


  • Closed Accounts Posts: 186 ✭✭mousehouse


    I do not see why BOI is still engaging in ridiculous conversation with the requests for on going lenghty comments on this matter.


  • Registered Users, Registered Users 2 Posts: 5,578 ✭✭✭Slutmonkey57b


    mousehouse wrote: »
    I do not see why BOI is still engaging in ridiculous conversation with the requests for on going lenghty comments on this matter.

    Errrrr? Because abandoning the thread on a poster who's making publicly embarrassing statements about the bank is *good* PR in your mind?

    I love these forums, this one might get as good as the Vodafone one. *fingers crossed*


  • Closed Accounts Posts: 20,373 ✭✭✭✭foggy_lad


    RangeR and zynaps,

    As I said above, we expect the majority of refunds to be immediate. There are situations where this is not possible. As a paying bank our obligation to a payer is to provide a prompt refund once it has been established that the direct debit was unauthorised. We're responsible for determining that the claim for a refund is genuine, which may require further investigation and/or more information from the customer.

    Thanks,
    Graham

    Where any amount or debit is disputed it is up to the Customers bank to refund them immediately! they them get a refund from the originating bank who get their money back from the company who must then get on to their customer and seek alternative payment of the debit amount if it is indeed due for payment.

    It is not up to the customers bank to investigate anything to do with the originator, all they are obliged to do is follow their customers instructions on how their account is to be managed!

    Obviously this will present issues where the originating bank os the same bank as the customer, the bank won't want to upset their business clients like upc meteor eircom BT etc etc so they don't refund the lowly peasant customers until they get permission from their business clients!


  • Moderators, Technology & Internet Moderators Posts: 12,450 Mod ✭✭✭✭dub45


    mousehouse wrote: »
    I do not see why BOI is still engaging in ridiculous conversation with the requests for on going lenghty comments on this matter.

    Indeed bank customers finally asking pertinent questions about the sham that is the direct debit system.

    How dare they!!!


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