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January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



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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: 2941
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: 30979
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: 2941
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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