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And then the last one is going to be payment applications. And this one's getting all the press these days. So think about PayPal, Apple Pay cash, and Venmo. Those are the ones I have listed. There are others out there. You can see them on the screen, Amazon Pay, Google Wallet, and there are probably other newer ones that have come out since we put this slide and these materials together. What's your responsibility? What's your liability for those transactions? Because many times, the customer authorizes it.
Well, let's just stop there. If the customer authorized it, do not have this discussion because that's an authorized transaction. That's not something we have to deal with under Reg E. But what if they've set up a payment app, and there's fraud on the other end of that? Somebody has gained access through that payment app to their bank account. Because how these payment apps work is, if I go to Venmo, Amazon, or Apple Pay, I can have an account directly with them, and the money is in that... I can have an Apple Pay wallet and put the money in the Apple Pay wallet; it doesn't come out of my bank account.
But a lot of those are required to be tied to a bank account. Well, if it's tied to the bank account, the transaction actually shows up on the bank transaction log, if you will. And so, is that yours or is that theirs? Well, the CFPB chimed in December of 2021 and said, here's the deal, folks. There's a loophole in Reg E, section 14, that says if you meet three pieces of criteria, you may not be responsible for the unauthorized transaction. However, let's find out what the CFPB said that is outside of that loophole.
Number one, if you were doing Zelle transactions, those are yours. If somebody comes to you with a Zelle transaction that they didn't authorize, or they feel it was a disputed item, then you have to deal with it. You have to resolve it under Reg E. Number two, debit card transactions. If the transaction flows through as a debit card transaction, you're on the hook. ACHs, that's the area where section 14, that loophole might exist where you can say to go and take it up with Venmo, or Cash App, or Apple Pay, or whoever. But there are criteria that have to be met there.
And again, that's something we'd get into in our longer Reg E session. The point is to be very careful with these. And this is part of the reason they're looking at redoing Reg E sooner than later. Because there are a ton of complaints that are coming into the CFPB about these third-party payment apps and banks not providing customers with any sort of refund or restitution. Well, under Reg E, in many stances, they don't have to. And that's not something that the CFPB likes very much in this instance. And so they're looking to possibly redo that along the way.
