Thoughts needed - had a debit cardholder call in on a Friday because his card was declined when he tried to use it on Thursday evening. Cardholder was informed the transaction was declined because he exceeded his velocity limit (# of times the card can be used in a 24 hour period). Explained to cardholder that he had met his velocity limit due to numerous Google charges being processed. Cardholder stated he wasn't sure about that. He said he does have a Google account & he would look into it. He did not seem too concerned about it. Now come the following week, a fraud alert is generated for the cardholder due to numerous Google transactions. He then states that these are fraud along with all the Google charges all the way back to January. Understand we must investigate 60 days from the first statement date. My question is ... he was informed of the transactions on Friday & chose not to do anything. What happens with all the Google transactions between Friday and the day the card was closed (about 4 or 5 days later when he claimed fraud). Is he responsible for those or does the bank need to investigate those as well. Thank you in advance!!

Cardholder stated he wasn't sure about that. He said he does have a Google account & he would look into it.

1005.6(b)(2) - Timely notice not given. If the consumer fails to notify the financial institution within two business days after learning of the loss or theft of the access device,

You notified your cardholder the card was blocked due to too many transactions to Google. Cardholder states he's not sure and will look into the transactions. At this point, I would not consider him to have knowledge of loss or theft. Less than a week later (4 or 5 days per your post) he confirms these as fraudulent transactions. Two of those days were non-banking days, so this is reduced really to only 2 or 3 days. When did he learn of the loss/theft? I would be hard pressed to argue against your customer. You notified, he said he would look, he did and states they're unauthorized all within a few days.

To add just a bit -

My wife and son have spent far more than I care to admit on Apple buying songs and games (in the case of my son). Charges from $0.99 upwards of $20 and everywhere in between. If my bank contacted me with concerns about these transactions, I would have to do the same thing as your customer. I would have to look and ask questions before I could determine anything and before I could state "these are unauthorized" or "these are all okay."