We are considering updating verbiage in our outbound letters and I was hoping to get some clarity regarding regulatory requirements prior to instituting said updates.

Per Reg E 1005.11(c)(2)(i) Provisionally credits the consumer's account in the amount of the alleged error (including interest where applicable) within 10 business days of receiving the error notice....

My question is per the reg are we required to notify the customer of the amount of interest we have credited back to the account or include that amount as part of the summed provisional credit when we notify the customer of the provisional credit issuance? I've been unable to identify any verbiage affirming this but wanted to reach out to others to see what the standard is at their institutions.

I can't give you a referenceable answer, but hopefully can still help. I had the same question, and posed it to a contact at the CFPB. They qualify everything as "Unofficial Guidance", so take that for what you will. In my case, the interest is always a separate credit to the account, so our PC letter states the amount and date of the provisional credit being issued, along with "Interest associated with the disputed transactions will be adjusted to your account, where applicable". The reason we don't include the interest amount is because the rate data is not available to the claims software, so it has to be manually entered by a user.

The CFPB stated that they would definitely prefer the letter to contain an exact amount to be credited to the account, but felt comfortable with the language used given that the alternative is to delay the credit to the consumer.

My response is more operational/customer service than regulatory. Imagine you have a customer that still balances their checkbook every month. How can they do this if you don't tell them how much you are crediting their account for?