Customer filed a Reg E dispute 2 years ago. We issued a final credit to the account within the appropriate time frame. Customer called us today (yes, 2 years later) to say they now know what that charge was and we can debit the money we credited them from their account. I know Reg E says final is final, so I was wondering, even if we have the customers permission to debit the account, can we?

Wow! What an honest person. If the amount is not large I would just tell them thank you and let them keep it.

If you want to recover the funds, send the customer a letter asking him to confirm his permission to do so by signing and returning a copy. Include a SASE to make it REALLY easy for him to provide you the signature.

Taking those funds with the customer's permission would not violate Regulation E. I'd just be more comfortable if the permission is documented.