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#2288223 - 08/31/23 02:25 PM Reg E Sub Part B - Procedures for resolving errors
Flower123 Offline
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1005.33(c)(1) A remittance transfer provider shall investigate promptly and determine whether an error occurred within 90 days of receiving a notice of error.

Is the timeframe referenced 90 business days or calendar days?

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#2288224 - 08/31/23 02:35 PM Re: Reg E Sub Part B - Procedures for resolving errors Flower123
rlcarey Offline
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"Business day" is specifically defined in the Reg E definitions. If the term "business day" is not used, then it is calendar days.
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#2288225 - 08/31/23 02:48 PM Re: Reg E Sub Part B - Procedures for resolving errors Flower123
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Thank you

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#2288226 - 08/31/23 03:09 PM Re: Reg E Sub Part B - Procedures for resolving errors rlcarey
Flower123 Offline
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That was my understanding however in the comments for 1005.30(b)-2

..... In this case, Saturday does not count toward the business-day standard set by subpart B for resolving errors, processing refunds, etc.

I do not see business day used in 1005.33 unless I am overlooking it somewhere?

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#2288227 - 08/31/23 03:18 PM Re: Reg E Sub Part B - Procedures for resolving errors Flower123
rlcarey Offline
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(c) Time limits and extent of investigation.

(1) Time limits for investigation and report to consumer of error. A remittance transfer provider shall investigate promptly and determine whether an error occurred within 90 days of receiving a notice of error. The remittance transfer provider shall report the results to the sender, including notice of any remedies available for correcting any error that the provider determines has occurred, within three business days after completing its investigation.

"Days" and "Business days" are used here. Since days are used, it would be calendar days for the 90-day time period, but reporting and notice is required in business days.
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#2288232 - 08/31/23 03:48 PM Re: Reg E Sub Part B - Procedures for resolving errors Flower123
Flower123 Offline
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Therefore the reference to "Saturday not counting toward the business-day standard" is only applicable to the three day reporting aspect and not the action of completing the investigation?

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#2288237 - 08/31/23 04:00 PM Re: Reg E Sub Part B - Procedures for resolving errors Flower123
rlcarey Offline
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That is correct.
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#2288245 - 08/31/23 04:42 PM Re: Reg E Sub Part B - Procedures for resolving errors Flower123
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Thank you, that clarification helps. Have a great day.

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