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#2301632 - 09/12/24 06:18 PM Reg E Time Lines
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,532
New York City
In what situations is the 90 day requirement to file a dispute extended to 120 days?
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#2301638 - 09/12/24 06:59 PM Re: Reg E Time Lines ACBbank
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,969
Illinois
Your question confuses me. What do you mean by "file a dispute." There is no statute of limitations for a consumer to file an error claim. 1005.11(b) notes the timeframe for when notice is not considered timely, but the commentary notes that for claims involving unauthorized charges, 1005.6(b) still applies whether the notice is timely or not.
Last edited by BrianC; 09/12/24 07:01 PM.
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#2301643 - 09/12/24 07:48 PM Re: Reg E Time Lines ACBbank
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,532
New York City
My apologies Brian. I should have stated the time we have to complete the investigation into a filed dispute.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2301648 - 09/12/24 09:05 PM Re: Reg E Time Lines ACBbank
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,969
Illinois
If the claim you are investigating an error defined in 1005.11(a) and it is a point-of sale claim, a new account, or a transaction not initiated in a state, you have 90 days. There are no extensions to 120 days anywhere in Regulation E.
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#2301649 - 09/12/24 09:07 PM Re: Reg E Time Lines ACBbank
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,969
Illinois
If the claim you are investigating an error defined in 1005.11(a) and it is a point-of sale claim, a new account, or a transaction not initiated in a state, you have 90 days. There are no extensions to 120 days anywhere in Regulation E.

If the notice of error is not timely as described in 1005.11(b), then the investigation requirements in the rest of 1005.11(c) & (d) do not apply at all, except you must still follow the liability schedule in 1005.6 for unauthorized transfers.
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