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#633754 - 11/02/06 10:01 PM Vagarities in 205.11(a)(vii)
jjames4317 Offline
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Joined: Aug 2006
Posts: 10
I am looking for comments on what constitutes
"for additional information or clarification concerning an electronic fund transfer" in the following section:

Section 205.11
(a) Definition of Error
(1)(vii)
"The consumer's request for documentation required by 205.9 or 205.10(a) of Regulation E or for additional information or clarification concerning an electronic fund transfer, including a request the consumer makes to determine whether an error exists under paragraphs (a)(1)(i) through (vi) of this section."

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eBanking / Technology
#633755 - 11/02/06 10:26 PM Re: Vagarities in 205.11(a)(vii)
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Oh, let's say the customer sees an ATM withdrawal without a location in the description (they are common if the ATMs are outside the U.S.). The customer might ask for more information (and you're unlikely to get it). Or the customer sees an ATM transaction he doesn't recognize, and asks for the time of day the withdrawal took place (because he was out of town part of that day).
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#633756 - 11/02/06 10:33 PM Re: Vagarities in 205.11(a)(vii)
jjames4317 Offline
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Joined: Aug 2006
Posts: 10
How about in relating this to a billpay inquiry, what if the customer calls to state that their payment was not received by the intended payee or that it was received but applied late?

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#633757 - 11/03/06 05:20 PM Re: Vagarities in 205.11(a)(vii)
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Those would both be 205.11 error claims, and would have to be investigated to the extent of the bill payment records (that would include looking at cancelled checks if payment was made by that method). But it would not require contact with the payee.

"We can confirm that payment was sent on xx/xx/xx and that the check appears to have been received and endorsed by the payee on yy/yy/yy. We are sorry, but we are not able to determine whether the payee credited your account there."
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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