We have customers who claim non-receipt of funds from ATM withdrawals at casinos. We've been using the standard 45-day timeline which sometimes expires before the processor's representment date. As such we close the case as required even though the claim may be rejected.

I noticed that some of these transactions come through as POS. Upon further research on the Internet, I discovered that this is being promoted by ATM companies as a way to get around the daily withdrawal limit imposed by banks.

Can we use the 90-day POS timeline because of the way the transaction is processed?

I have seen transactions from these types of machines. Not a true ATM. The cardholder enters their PIN into the machine and receives a receipt which they then must bring to a cashier to obtain their chips.

For Reg E purposes, since these are routed through the network as point-of-sale, you are permitted the extension to 90 days to complete your investigation.

Thanks for the input. This is very helpful. While we want to assist the customer as much as we can, we don't want to shortchange ourselves on the investigation time.