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April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina

May 15
Managing Electronic Information - From A to Zettabyte
Fred Menge



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#1680327 - 03/21/12 12:07 PM Provisional Credit Reg E
LadyLady Offline
New Poster

Registered: 03/21/12
Posts: 5
If provisional credit is issued upon verbal notification and our institution requires written confirmation, can the credit be revoked if we do not receive the written confirmation by the 10th business day? This revocation would not be as a result of a final decision, but as a result of not receiving the written requirement.

Or, must provisional credit be maintained until the completion of the investigation, without regard to the written confirmation requirement?

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eBanking / Technology
#1680343 - 03/21/12 12:29 PM Re: Provisional Credit Reg E [Re: LadyLady]
BrianC Offline
Power Poster

Registered: 11/26/04
Posts: 2623
Loc: Illinois
If you require written notification as a condition of providing provisional credit, do not provide provisional credit until you receive it. Once provisional credit is provided, the only allowable reason the regulation has for revoking it is when/if you determine that no error occurred as stated in 1005.11(d)(2)
_________________________
I can do all things through Him who gives me strength. (Phillipians 4:13)

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#1680429 - 03/21/12 01:34 PM Re: Provisional Credit Reg E [Re: LadyLady]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 29464
Loc: Cape Cod
If you require written confirmation as a condition of providing provisional credit, I agree you shouldn't provisionally credit the account until you receive the confirmation (and you don't ever have to provide it if the confirmation doesn't reach you until after the 10th business day following the oral claim).

One caveat, though -- if the claim involves both Regulation E and a debit card transaction subject to Visa's zero liability requirements, you have to provide provisional credit by the fifth business day, and I believe you can't condition it upon receipt of the written confirmation (Brian will confirm that or set me straight, I am sure).
_________________________
John S Burnett
BankersOnline .com

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#1680518 - 03/21/12 02:27 PM Re: Provisional Credit Reg E [Re: LadyLady]
BrianC Offline
Power Poster

Registered: 11/26/04
Posts: 2623
Loc: Illinois
As much as I'd love to set John straight...I will confirm his statement. VISA only requires oral notification for your provisional credit obligations to kick in.

This change was effective October 15, 2011 when VISA no longer required a cardholder letter for an issuer to file a chargeback. (Note that some processors have not updated their dispute procedures to allow for this and may still require a customer letter to begin the chargeback process.)
_________________________
I can do all things through Him who gives me strength. (Phillipians 4:13)

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#1680700 - 03/21/12 05:14 PM Re: Provisional Credit Reg E [Re: LadyLady]
LadyLady Offline
New Poster

Registered: 03/21/12
Posts: 5
Great info guys. Thank you very much.

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