On the dispute form my bank currently uses, it gives the customer the option to select "Card Lost, Card Stolen, Card In Cardholder Possession" but I know that an access device can mean the card number and not the physical card. 100% of the time everyone choses "Card in Cardholder's Possession" - how can do you figure out if an access device was used or not to impose liability?

When I took this position, there was no mention of imposing customer liability and I haven't seen that they've done it in the past. How can I start doing this?

(a)(1) “Access device” means a card, code, or other means of access to a consumer's account, or any combination thereof, that may be used by the consumer to initiate electronic fund transfers.

What other sort of access device would you issue the customer outside of a physical card? Just because someone may be in possession of their card number does not mean they have stolen the access device.