I am just learning reg E, so please excuse me if this is a silly question.

What happens if we are not able to resolve a debit card dispute within the 45 day time frame. Are we just out the money?

It's not a silly question as Reg E is extremely confusing.

First, if you disclose properly, you could extend a debit card dispute to 90 days instead of the 45 days. If you do get to your time limit (45/90), then you are required to close the investigation regardless of whether or not you were able to fully resolve the dispute within that time frame. So, yes, you would probably be out the money.

That said, there really are two different investigations: 1 for the customer (45/90) and 2 for the bank. The customer investigation is required to be closed and final for the customer within 45/90 days but the bank investigation could go on forever. Basically, if you were able to get your funds back from a merchant 5 years later (yes, highly unlikely), then you could recover your funds.

The bottom line is that the investigation for the customer must be closed within the 45/90 time limits.

Thank you. That was very helpful!