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Handling Reg E "Dated" Claims

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Question: 
In July, a customer submitted a Reg E dispute for debit card transactions which happened in March, April, and May. The first statement was in April. The customer still has his card. The dispute team processed the claim, eventually finalizing it by crediting the customer for the first statement plus 60 and denying the remainder. Earlier this month (September), the customer filed another claim for the same merchants but for an earlier period, December-February. Do you agree that this must be treated as a separate claim because the first one was already made final? If the second claim came in before the first was closed I am assuming we can combine the two since the same merchants are being disputed.
Answer: 

I agree it is a separate claim. Although the regulation does not require it, when I teach Reg E, I encourage institutions to review transaction activity prior to the transactions that are being disputed to try and avoid the consumer double dipping on the claims process.

First published on 12/29/2024

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