P2P Claim, No Agreement with Vendor

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Question:

I have a Reg E Section 1005.14(a) question. If a consumer is disputing a charge that originated as an ACH from a P2P or other fintech and we do not have an agreement with the P2P or other fintech, can we as a financial institution direct the consumer to file their dispute with the P2P? Aren't they subject to Reg E Section 1005.14(a)?

Answer:

In such cases, you should tell your customer that the error claim should be filed against the P2P/fintech.

However, the CFPB has made it clear it believes that when the transaction hits the bank as a debit card transaction, the claim should be handled by the card-issuing financial institution.