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#1903242 - 03/07/14 03:32 PM Reg E-Debit Provisional Credit
JacksTigger Offline
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JacksTigger
Joined: Jan 2010
Posts: 265
lost in compliance land
Need Reg E experts

Here is the situation--Customer makes a error claim, Bank gives provisional credit while we investigate, yesterday we got notice that the merchant had refunded the customer the funds (customer now has gotten funds twice).

When we debit the provisional credit, do we need to honor the items that would have cleared for 5 days or not? I know the rule says we have to when we determine there was no error. But in this case, the customer got double.

My instinct is to honor the items, but wanted another opinion.

thanks
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eBanking / Technology
#1903249 - 03/07/14 03:41 PM Re: Reg E-Debit Provisional Credit JacksTigger
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
I always send my customer a letter stating that I have completed my investigation and determined that an error did occur, but that the merchant issued a duplicate credit. I then advise the custoemr that I am reversing the duplicate credit, not the provisional credit. Since the customer has been made whole and you have found in their favor, I do not see a need to honor overdrafts for 5 business days.
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#1903299 - 03/07/14 04:28 PM Re: Reg E-Debit Provisional Credit JacksTigger
JacksTigger Offline
Gold Star
JacksTigger
Joined: Jan 2010
Posts: 265
lost in compliance land
ooh--"duplicate credit"--good word choice. wink

Thanks, in this instance, ops had already sent out our letter saying we would honor overdrafts, but now we can revise our wording to "duplicate" for when this happens in the future.

Appreciate your time.
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Don't cry because it's over. Smile because it happened ~ Dr. Seuss

CRCM

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