Having a mind block for Visa compliance: How long can we wait to give back the funds customers have lost with debit card fraud. Today we are not giving provisional credit for up to and beyond 10 days.

Thanks

Both VISA and Mastercard give you 5 business days which is less than the 10 business days allowed under Regulation E.

5 ??? I don't think I knew that...uh oh....
is that in dog years ??? ughhhh

5 days is correct for Visa's zero liability - this applies for any POS signature transactions routed through Visa. 10 days under Reg E would still apply for PIN transactions routed through a network other than Visa. I believe PIN transactions routed through Visa would be limited to 5 days as well.

To keep it simple, we just aim for 5 days on all. Most of our fraud is signature based anyway. We might extend up to 10 on an ATM dispute if we're trying to get film.

I'm confused. I attended the BOL webinar on debit card claims 06/15/11, and am looking right at my docs. It states that "Visa" only reduced it to 5 days.
Did something change ?

Ya know, I thought MC's policy provided the same as Visa, but not being completely sure I really shouldn't have included that. Will remove the MC references from my post.

Since I gave the aforementioned webinar on 6/15/11, I had best chime in here.

VISA's website/operating rules are very clear about the 5 day requirement:

Count on quick resolution and provisional credit if your card is lost or stolen. If your account is compromised, Visa is committed to setting things right without further aggravation or inconvenience to you. Visa’s cardholder protection policy requires all financial institutions issuing Visa products to extend provisional credit for losses from unauthorized card use within 5 business days of notification of the loss.

MasterCard is mute on the issue of provisional credit. Consequently I also maintain that you are fine observing the Reg E requirement of 10 business days if you are a MasterCard issuer.

Thank you Brian C-we were almost to arm wresting over it here...:)

Brian, Any update available on the VISA provisional credit rule? Chase Bank is telling me they aren't going to issue provisional credit at all until the case is closed 45-90 days. Unauthorized use, approx 13K fraud claim. They are telling me since it's a business account and less than 180 days old, they need to protect themselves. Can they legally do this, my business credit worthiness and credibility with my creditors will be ruined.

Brian, do you have information on what consequences the financial instituion (issuer) could face if not following the 5 day zero liability rules?

Anon, I cannot speak to the practices of a specific institution as I do not know the terms under which your card was issued. Your best course of action would be to have an attorney review your cardholder agreement to see if Chase has violated it in anyway as this would be a matter of contract law.

Happyauditor, VISA discloses non-disclosure fines on page 68 of the October 15 , 2013 edition of VISA International Operating Regulations