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#1961759 - 09/12/14 08:28 PM Reg E POS Fraud Dispute
JoaSmith14 Offline
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Joined: Sep 2014
Posts: 1
Does Reg E REQUIRE a financial institution to submit a fraudulent dispute for a customer even after 60 days after a statement has been generated showing the transacton to be disputed, if the customer requests us to? I understand that we do not have to give conditional credit after the 60 days, but are we required to submit the dispute to be investigated?

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eBanking / Technology
#1961769 - 09/12/14 08:44 PM Re: Reg E POS Fraud Dispute JoaSmith14
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Submit it to whom? And why would provisional credit have anything to do with 60 days????
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#1961795 - 09/12/14 09:36 PM Re: Reg E POS Fraud Dispute JoaSmith14
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#1961799 - 09/12/14 09:42 PM Re: Reg E POS Fraud Dispute JoaSmith14
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,840
Illinois
Your obligations under 1005.11 to investigate a claim and to pay provisional credit go away if a customer does not provide timely notice. However, the liability schedule in 1005.6 still applies to any unauthorized transactions. So if a customer reports a transaction from January as unauthorized you are liabile for any unauthorized transactions up to 60 days after you deliver the January statement and the customer has unlimited liability after that. It is up to you if you begin an investigation to determine if the transactions are unauthorized or if you pay the claim immediately.
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