This may have been addressed, if so please let me know where to find it.
Customer notifies us in June of unauthorized transactions from Feb statement. I know I have to recredit for the transactions during the first 60 days from first error but do I have to abide by the provisional credit time or can I wait until the investigation is complete?? ( I do have a signature from customer) Also, is there any statue of limitations for the time that the customer can come back and ask us to recredit? i.e. can they come back 1, 2 years etc. after the error? Or would this fall under state laws?

Aside from the 60 day statement (assuming not hospitalized, etc.) there really isn't a time limit. They increase their liability for those continuing transactions.

And the timeline to investigate is cut and dry. Extensions because of the age of the claim are not provided for. If it isn't done in 10 business days, provisional is needed and you (generally) have up to 45 calendar days.

Let's assume the customer's February statement is cut 2/28/2003 and is available on March 5. The customer has until May 4 (60 days from March 5) to assert the claim under §205.11. If the claim is submitted later than May 4, §205.11 error resolution requirements do not apply.

The customer's notice in June is plainly beyond this deadline. Therefore, you should not have to provide provisional credit, and you should not be found wanting if your research takes you longer than 45 days.

However, as you've pointed out, the §205.6 rules on liability still apply. If your investigation leads you to believe they are unauthorized, the transactions on the February statement, and any taking place in the 60 days from March 5 (statement availability date) will not be the customer's responsibility. This 60 day period may be extended under "extenuating circumstances."

There is no statute of limitations on when the claim must be filed, unlike those found in the UCC applicable to paper items.

Thanks Andy. That was my interpretation but needed a confirm.

To be more clear, the customers liability isn't changed, but John's point on the investigation requirements is definitely valid. 205.11(b) spells out that this section applies when you get timely notice (w/in 60 days of the statement).