08/18/2008
As it relates to Reg E claims, I need clarification:<ol><li>is an internet purchase considered a POS<li>is a telephone purchase considered a POS</ol>I'm trying to utilize the POS 90 day extension time period. The reg is not straight forward in this regard.
07/14/2008
A consumer files a Reg E claim stating the merchant charged a different amount than authorized. The customer cannot provide receipts and the authorizations were for the amount being disputed. Do we still need to proceed with the claim or can we deny it based on valid authorizations because customer can't prove amount authorized?
06/30/2008
I work for a small institution where we do not have cameras at our ATMs, and we are finding more and more that banks are unwilling to release photos on ATM transactions when unauthorized transactions occur. We cuurently have a client that is disputing three ATM withdrawals totaling $1,160.00. She had her card in her possession at the time she went to the branch to file the dispute. She claims no one has access to her card or PIN. There have been no attempts to use the card number since the day it was blocked, leading me to believe her card was not skimmed. I would like to request ATM pictures, if possible. They were done at three different PNC ATMs in Philadelphia. The bank has already informed us that they will not release photos.I see this as a simple denial because the customer has card and pin in her possesion. Would everyone else just deny this claim. If so, and customer re-asserts the claim, what would be some of the actions one might take to help resolve it for the customer?
05/12/2008
We have a customer that is disputing charges that had been done with her Visa/Checkcard. She just notified the bank last week, but after researching some of these charges took place back in Dec. 2007. The customer receives their monthly statements by e-mail, but according to them they have never been able to access these statements. But we have documentation that shows they view their account on a weekly basis from our website. What is our responsibility to our customer when in fact we know they were negligent?
04/07/2008
I do not mean to sound like such a dummy, but I am so confused about Reg E compliance. I understand that we are required to investigate all card transaction disputes, but does Reg E require us to give a provisional credit on all claims? I am particularly disturbed that the bank, due to the provisional credit requirement of Reg E, ends up writing off claims for which we cannot recoup any losses. Since customer initiated transactions are not considered to be "unauthorized" by the processor and we cannot enter a valid dispute, we will always have to absorb the loss to comply with Reg E. It does not seem fair.
03/24/2008
Reg E requires us to investigate all claims of unauthorized card transactions. Would a claim fall under Reg E provisional credit guidelines when the customer initiates a transaction and later wants to dispute the amount charged by the merchant?
01/07/2008
We continually receive disputes involving minor children (under age 18) who have purchased a product on the internet using their parents debit card number for payment. The parent files a claim for unauthorized transaction. Obviously, they refuse to get a police report as we normally require to continue the investigation. The parent tells us the child made the transaction, but they (the parents) did not authorize it. Can the fact that the parents are responsible for actions of minor children living in their house and using their equipment be our defense for denying the claim?
12/17/2007
The passage below is part of John Burnett's response to a Reg E question concerning unauthorized transactions reported beyond 60 days from the statement delivery date. For example, if there was an unauthorized transaction (no access device used) that appeared on the customer's June statement and he or she is just now reporting it, must the bank reimburse the customer? My bank has been denying these claims as too old. Based on everything I've read, I believe the customer is not liable for these initial transactions, even though they appear on earlier statements. I am wondering what John meant by "unless the transaction is one in a series" in the article below. Could someone elaborate please? Your consumer/customer is entitled to enter a claim with you that an entry was unauthorized at any time (the 60 day limit in section 205.11 only covers the customer's right to the procedures in that section, not the customer's liability for unauthorized transfers, which is found in section 205.6). If the transaction is unauthorized, the customer is entitled to a refund unless the transaction is one in a series and took place more than 60 days after the statement was available that showed the first unauthorized transaction in the series.
12/10/2007
I have a question about Reg E. We have situations with customers who are not happy with the goods or services they purchased using an access device and they come to us wanting a refund. Do these claims fall under Reg E? The seven errors identified under Reg E say nothing about being satisfied with goods or services from what I can find. If it does not fall under Reg E, can we require them to try and resolve the claim with the merchant?
11/05/2007
We have a Reg E claim for a foreign ATM. The client claims he or she did not receive all of the money requested. We did a charge back and the terminal owner refused it. Arbitration is more than the claim, do we have any other options to get this money back?