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#1539139 - 04/21/11 09:47 PM REG E
szwick Offline
Member
Joined: Apr 2008
Posts: 71
I suddenly became very confused. We had a dispute and gave the customer immediate provisional credit. The dispute was denied as more information was required. This was relayed to the customer but they have not made any attempt to get us the information. How long do we wait before debiting her account? I want to debit it now and close the dispute.

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Operations Compliance
#1539168 - 04/22/11 02:41 AM Re: REG E szwick
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,925
Illinois
Quote:
The dispute was denied as more information was required


I'm a little confused by this statement. The only information that Reg E requires that which (ii) Enables the institution to identify the consumer's name and account number; and

(iii) Indicates why the consumer believes an error exists and includes to the extent possible the type, date, and amount of the error
.

You can request, but not require additional information.

If, during the course of your investigation, you make the determination that the customer did in fact authorize the disputed charge, you may deny the claim immediately and revoke the provisional credit. You must notify the customer in writing within three business days of your decision and honor checks and drafts up to the amount of the provisional credit for 5 business days after you revoke the credit. Also, you must provide, upon the customer's request, the documentation on which you based youer decision to deny the claim.
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#1539587 - 04/22/11 05:16 PM Re: REG E BrianC
szwick Offline
Member
Joined: Apr 2008
Posts: 71
Thank you crownman3,

This is a POS dispute and the card company has rejected the dispute. They are requiring more information. So if I understand correctly we can request the information but if the customer does not supply us with that the bank is proud owner of the charge?

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#1539893 - 04/22/11 08:20 PM Re: REG E szwick
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,925
Illinois
It depends on what you received back from your processor. If they are requesting additional information such as the cardholder required merchant contact for certain disputes, you can't deny the claim on this basis, but you can file a retrieval request without the cardholder letter. This will at least compel the merchant to provide the authorization information to aid in your investigation.

If the cardholder initially claimed fraud, and the processor responded with a transaction that had a name/address match and requires an updated cardholder letter for a second chargeback (MC) or pre-arbitration (VISA) I will contact the cardholder advising them that we need the updated letter. I further state that if they fail to respond to our request, I will use the name/address match as grounds to deny their Reg E claim. This usually gets them into the bank. VISA/MC give you 30 days to obtain the letter and continue with the investigation. Once that time elapses, then I will deny the Reg E claim and revoke the provisional credit.

Let me know if I can provide additional clarification to your specific situation.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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