We were alerted by a service provider of some unusual debit card activity on a customers account. We sent a letter to the customer asking if these charges were legitimate. They replied back that they were not and we began the error resolution process. The commentary on Reg. E says that the consumer liability rules do not apply when the bank identifies the error and corrects it on its own. My question is when does the bank cross the line from correcting it on it's own to correcting the error when notified by the customer?

I would say that since we contacted the customer and they verified that the transactions were invalid then Reg. E would apply.

"do not apply when the bank identifies the error and corrects it on its own"

Just based on that statement, I would say it does still apply. It wasn't corrected on its own, the customer had to request it be corrected, though the conversation was initiated by you.

I think the identified and corrected on its own would be more in the case of a vendor double-posting and things such as that.

That's what I figured too Matt. Thanks