We have a customer who had fraud that started back in May of 2024. The customer notified us in August of 2024. The address we have on record where his statements were being mailed was his parents address. The customer stated he has been living away from the address on record for a while prior to the fraud occurring. Our terms and conditions state it is the obligation of the customer to notify the bank of any name or address change and that we will only communicate with the customer through the most recent information you provided the bank.

That being said, how would this impact the banks responsibility to provide provisional credit to the customer. Had we had the most recent address information the customer would have received his statements in a timely manner.

Many people nowadays get their statements online, so changing their address on file doesn't cross their mind. As to how this impacts provisional credit, remember the 60 days is a limit on liability for the FI that addresses the idiot customers. The customer could just as easily receive statements and go back a year or more for the initial fraud claim, but they will never get back more than that 60 days.

Regarding the requirement for provisional credit, I would suggest reviewing the CFPB Official Interpretation regarding late notice: