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Reg E Claims For Transactions Occuring Outside The United States

Answered by: 
Andy Zavoina

Question: 
We have a Reg E claim from a customer for some transactions that were done outside the U.S. He gave his sister his debit card and his PIN, but she is claiming that she did not do these transactions. I know normally we aren't liable if the customer gives out the card and PIN and doesn't let us know if that authority has been revoked. My question is, since she is stating that she did not do these transactions, what is our liability? How would I go about researching a claim on transactions done outside the U.S.? My 20 days is ticking by quickly!! Any help will be much appreciated.
Answer: 

The good news is that you have 90 days since this happened outside the U.S. The bad news is that you have that additional time to finalize the claim because there will be extra work. You should follow similar procedures working back through the networks you use, with the merchant or ATM owner.

I believe the basics still will apply, the account owner didn't complete the transaction, authorize the transaction or receive benefit. The claim should be handled as valid. But I would strongly consider not reissuing a card to the customer and I would certainly impose upon them any liability possible.

Section 205.11 Procedures for resolving errors.

(ii) The applicable time is 90 days in place of 45 days under paragraph (c)(2) of this section, for completing an investigation, if a notice of error involves an electronic fund transfer that:

(A) Was not initiated within a state;

First published on BankersOnline.com date 11/04/02

First published on 11/04/2002

Filed under: 
Technology
Filed under technology as: 
ATM
Claims

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