07/12/2010
We use a vendor to clear our transactions. They require a signed form noting the specifics about which a dispute is concerned. Yet, Reg E appears to say, the customer does not have to sign anything, yet we are to investigate. If the vendor will not accept oral requests, then we are potentially out the money unless we can find a legitimate reason to decline the dispute. Yet, they say they are Reg E compliant. How can this be?
04/19/2010
How do you determine the difference between a "check card dispute" and "check card fraud?" If a customer claims he did not make the transaction, but the merchandise was shipped to his address, can we deny the claim? If a merchant verifies the security questions through Visa, and the transaction is approved, is the bank obligated to reimburse the customer?
02/22/2010
If a customer says that there are transactions that she didn't authorize on her account, we usually ask questions to determine whether the customer participated in the transaction. When the person tells us that her daughter and granddaughter has access to her card and PIN number, do we still have to follow Reg E rules or can we tell her that she doesn't have any chargeback rights? Naturally, neither the daughter or the granddaughter did the transactions according to "grandma".
07/20/2009
The bank had multiple customers who were victims of the massive debit card breach in late January. Customers notified bank of these unauthorized POS debit card transactions in early to mid February and provisional credit was given at that time. Our bank does not investigate these disputes, instead we send them to our processor who investigates these claims for us. Our processor is overloaded with such claims from many banks, so we still haven't heard back from them on most of the claims we sent to them for investigation. The ninety day investigation period has now been exceeded, but we still have not been notified of the outcome of the investigation. What do we need to do at this point, continue to wait or issue notices to these customers telling them the provisional credit is final (and take the loss on any dispute that once investigated isn't a valid claim)?
05/18/2009
Does the 10-business day timeframe for Reg E claims begin the day we receive the claim or at midnight of the day we receive the claim?
05/18/2009
We have a customer who placed an order for a product, the company contacted them to say it no longer had the product, but could make a substitution for a different product at a higher price. The customer agreed and was charged for substitution. No merchandise has been received and the company has refused to refund them. Do we, as the bank, have to just give him his money back? We cannot go through Mastercard now because this is past the 120 days for charge back rights.
04/13/2009
I am learning to do the ATM/Debit card disputes and am confused about what is a Reg E error and what is a charge back. Can you explain the difference-in plain English, please?
03/30/2009
Reg E covers fraudulent transactions or unauthorized transactions not conducted by the customer/consumer, but does it provide protection for non-fraud cases? We receive a large amount of disputes where customers have purchased trials or samples from a merchant and are billed a few weeks later for additional products shipped to the consumer. We are under the understanding this is not covered by Reg E as far as provisional credit is concerned, but as long as the customer returns the unwanted products VISA grants a certain amount of protection as long as the customer did what was necessary.
03/02/2009
Reg E Commentary 205.11(a)-4 requires banks to comply with error resolution procedures for claims on closed accounts. However, Reg E does not provide guidance on how to provide provisional credit in such cases and 205.11(c)(2)(i) indicates crediting customer's account. Our thoughts are to credit another account owned solely by the customer and if no such account exists, to ask the customer for direction on providing provisional credit. If a customer requests a check in the amount of the credit, is a bank required to deliver a check since this provisional credit cannot be reversed as provided by 205.11(d)(2) if the claim is denied?
02/23/2009
A customer is claiming unauthorized debits to her account. She said she just realized this, but she claims the first occurance was in May. The $200 ACH debits occured every two weeks for several months. The debits were payments on a bill she owes. She said she authorized $50 a month. I realized I only have to reimburse for the debits occuring 60 days after the statement cycle in which the error occured. So far, I am not having much luck with the third party on getting proof our customer authorized the $200. It is too late to return the ACH's for unathorized. Our customer has benifited from these ACH debits in that her outstanding debt to this company has been reduced. Can we deny that claim based on the fact the she has benefited?