09/17/2007
Could you direct me to some guidance with regard to Reg E disputes relating to claims by client that he/she has cancelled a recurring service? We seem to get confused as to what we need to be doing from a compliance perspective vs. what our card processor (acting on our behalf with Visa) requires in terms of documented actions taken by the client to resolve the charges assessed after the alleged cancellation.
07/23/2007
Reg E applies to someone who is a "natural person". Does this mean that a non-resident alien who is issued an access device is not able to submit Reg E claims for unauthorized transactions?
02/19/2007
This question is in regards to Reg E and a claim of unauthorized use of an ATM card. Our customer claims that their wallet with their ATM card and PIN was stolen while they were incarcerated. The customer alleges that they was incarcerated "sometime in June" and released in December. They are calling now, in January, claiming that they just discovered that the transactions had taken place. Can we send him a letter stating that he did not respond within the appropriate time frame and is therefore liable for the transactions?
02/19/2007
A Customer is disputing unauthorized transactions that have taken place at the pump, but for those transactions you need the actual card. The customer claims they have the card and that someone must have got their account number. All the transactions have taken place at the pump in another state and the customer says they were not in another state. How can this be a valid dispute?
01/29/2007
Our customer is disputing transactions which were all conducted in another state. The customer claims he has never been in that area when transfers took place. He also states he has his card in his possession and believes someone may have gotten hold of his card number. How can this be a valid dispute? Could it be a duplicate card was created?
11/13/2006
Is there any scenario in accordance with Regulation E when the originating bank has the ability to return/reclaim the funds for an ACH claimed as unauthorized by their account holder?
11/06/2006
If you have a customer with an ATM dispute claim, who has in writing stated that his wallet was stolen with his card, his PIN and his account number in it, are we allowed to reverse provisional credit under Reg E?
10/30/2006
When a customer returns merchandise they purchased and requests a refund, how long does the merchant have to refund the customer and when should they come into their financial institution to make a Reg E claim?
10/09/2006
We have a customer who has filed two ATM withdrawal disputes with us. For both disputes, occurring on two different occasions, our customer claims that he went out, got extremely drunk and lost his card. He claims his pin was not written anywhere nor did he give it to anyone. He claims he can't remember the events of the evenings because he was too drunk but that he did not make these charges. According to Reg E, do we have the right to deny him due to negligence and not being able to provide us sufficient information?
08/28/2006
Reg E allows you to wait 10 days to provisionally credit the customer, and if you require that they send it in writing, and they do not, you do not need to provisionally credit their account. However, as the VISA rules require provisional credit at 5 days, our bank has been giving everyone provisional credit immediately. So our question is, can we reverse our provisional credit if the customer does not send us the information in writing? The regulation only talks about waiting until the resolution of the dispute to reverse the provisional credit, but we're wondering if it's okay to do so if they don't return the dispute in writing?