Hi All,

Can the bank require the debit card holder to make a regulation E claim (Unauthorized claim)? Example: I have an account where customer 1 is making a claim on customer 2's card where they are both joint account holders. Can you point me to the part of the regulation that addresses this issue.

1005.11(b) simply states that you must investigate when you receive notice from "the consumer." It does not specify that the consumer must be the owner of a specific card on which unauthorized electronic funds transfers took place. Any account owner can assert a claim of an electronic funds transfer error. The fact that your card processer requires a signed letter from the cardholder as a condition of filing a chargeback does not change your obligations under Reg E to investigate the claim.