Hello all! I would appreciate any thought, guidance and/or interpretation you may provide to the following scenario:

October 2016 a customer contacts the bank asking that her Visa Debit Card limit be raised to $10,000 (we do allow this for a temporary time frame with officer approval) to do an online brokerage transaction. The customer seemed confident with making the transaction. The required form was completed and approved. (Believe me, this is something I'm trying to get changed).

November and December 2016 - same scenario for $5,000 and $5,000. The Personal Banker inquired a bit further and found out the company with which she was doing business was in the UK. Basically the customer was "warned" of the risks, that there had been a lot of fraud schemes reported in the UK, etc. and the customer informed the PB that she had done business with the company before and they were fine.

Fast forward mid to late July 2017 - 7 to 9 months later. The customer wants to file a dispute. She had just recently tried to get her money back from the company to no avail and determined it was indeed fraud. She initiated the transactions. Bank personnel informed her of the risk of doing these transactions over the internet with a company in another country. She did it anyway.

What is the bank required to do considering she did authorize the transactions and the length of time between transactions and notifying the bank? Let her dispute? Give or don't give provisional credit? From what I understand with Regulation E the time frame is past and it wasn't truly "unauthorized". But Reg E is very confusing to me. And, it seems to me (in my opinion), it doesn't mesh with Visa Rules.

Any help would be greatly appreciated. Thank you in advance!!!
~DeDe

Let her dispute and deny the claim. It is not covered under either Reg. E or zero liability.

Thank you Mr. Carey. So, if she disputes and our service provider sends it back as no charge back rights, she's just out the money, right? The bank isn't liable in any way, right?

I wouldn't involve your service provider, Randy saying "let her dispute it" means, let her make a dispute claim to you - what you do with it (process a chargeback, etc.) is besides the point. Since you know she did in fact authorize it, all that is going to be involved is (1) She makes a claim, (2) you send her a denial letter.

I suppose if there's some type of chargeback right under Visa/MC for that transaction and merchant and she provides you with a written statement and there is a corresponding Visa/MC chargeback reason you might be able to try and process a merchant dispute, but it doesn't have anything to do with Reg E.

Thank you so much for your feedback and help!!!! These situations drive me crazy! LOL!