Here's how Comment #2 to ยง 205.11(c)(4) puts it:
"2. Scope of investigation. When an alleged error involves a payment to a third party under the financial institution's telephone bill-payment plan, a review of the institution's own records is sufficient, assuming no agreement exists between the institution and the third party concerning the bill-payment service."
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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