Scenario - a customer initiates a Reg E INQUIRY on day 1. Bank provides info to satisfy. After reviewing the info, the customer wishes to report an ERROR on day 5 (same transaction). Would you begin the DISPUTE timeclock on day 1 or day 5, and why? (In other words, would you categorize the INQUIRY and ERROR as two separate events, or as one?)

Technically, the inquiry is an error claim under 205.11(a)(1)(vii), unless it's clear the consumer is only requesting copies, etc., for tax records or similar purposes. When the bank provides the information requested under 205.11(a)(1)(vii), that error investigation is considered closed.

When the consumer asserts an error claim based on the information provided, a new error claim is opened, and a separate, albeit related, investigation begins, with a new "Day 0" from which to begin. Also remember that the 60-day period for filing claims is reset to zero when you supply information under 205.11(a)(1)(vii).

OK. That makes perfect sense. But then I get confused reading 205.11 (e) Reassertion of error, and moreso the official staff interpretation at the end of the reg on this section, given that an inquiry IS an error. What am I missing?

The customer is not reasserting the first error. The first error claim was really a request for information, which the customer received.

Now the customer is claiming an error about a transaction. That's a new claim, not a rehash of the old one (even though it has a relationship to it). In other words, the customer isn't again asking you for information about the transaction; he's claiming there's something wrong with the transaction.