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#1676375 - 03/12/12 02:07 PM Reg E Error Resolution

For error resolutions, I was curious to see how many banks actually require written notice from their customers for provisional credit. Our current process is to receive a written letter and an affidavit. To me this just seems like duplicate info.

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#1676513 - 03/12/12 04:42 PM Re: Reg E Error Resolution [Re: Anonymous]
John Burnett Offline

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Registered: 10/27/00
Posts: 32400
Loc: Cape Cod
Not only is it likely duplicative, it may be a violation of the regulation. All the notice has to include in order to meet the requirements of the regulation is that it:

"(i) Is received by the institution no later than 60 days after the institution sends the periodic statement or provides the passbook documentation, required by 1005.9, on which the alleged error is first reflected;

"(ii) Enables the institution to identify the consumer's name and account number; and

"(iii) Indicates why the consumer believes an error exists and includes to the extent possible the type, date, and amount of the error, except for requests described in paragraph (a)(1)(vii) of this section [a request for documentation or clarification of the transaction).

Requiring an affidavit is, in my opinion, overreaching by the bank.

Edited by John Burnett (03/12/12 04:42 PM)
John S Burnett

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#1676644 - 03/13/12 09:06 AM Re: Reg E Error Resolution [Re: Anonymous]

What about for section 1005.11 that deal with debit cards. In our Reg E disclosure we state if we require you to put your complaint or question in writing and we don't receive in 10 business days we don't have to give you provisional credit.

I was just curious to see if any other banks require their customers to put their debit card disputes in writing?

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#1676875 - 03/13/12 12:55 PM Re: Reg E Error Resolution [Re: Anonymous]
BrianC Offline
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Registered: 11/26/04
Posts: 3188
Loc: Illinois
Section 1005.11 does permit you to require written notification prior to providing provisional credit. My institution still does. John was responding to your statement that you require both a written letter and an affidavit. The Reg permits you to require a written letter. It does not permit you to require an affidavit.

I agree with your original post that having both is redundant and it light of John's comments, not a good idea. Scrap the affidavit.
I can do all things through Him who gives me strength. (Phillipians 4:13)

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