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Reg E Error Resolution Process-Provisional Credit

Answered by: 
Randy Carey

Question: 
As part of the Reg E Error resolution process, (for an unauthorized debit card transaction), are we required to send a letter to the customer once the case has been investigated to let them know whether provisional credit will be rescinded or not? Currently we are only sending a letter when provisional credit is being revoked, not when the customer is being allowed to keep it.
Answer: 

by Randy Carey: There is no requirement to send them a letter, but they must be notified.

1005.11(c)(2)(iv) Reports the results to the consumer within three business days after completing its investigation (including, if applicable, notice that a provisional credit has been made final).

Answer: 

by David Dickinson: Randy's right, but I always recommend ALL correspondence on Reg E error resolutions be in writing. How else do you support when/how you informed the consumer? These can also easily turn into civil issues. I'd have a form letter for all Reg E notifications.

First published on 11/11/2018

Filed under: 
Compliance
Filed under compliance as: 
Error Notification
Reg. E

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