I understand the Joint Overdraft Guidance states that overdrawn accounts should be charged off after 60 days. Is there anything that would allow for an extension past the 60 day mark? (i.e. a fraud investigation, pending transactions, approval from upper management, etc.)
How many OCC examiners are there?
What action steps are needed when we find a severe or frequent violation?
How is the Comptroller’s Handbook organized?
Regarding Reg E and tier three timely notification: if a cardholder submits a dispute stating fraud occurred 5/1/20, our institution would apply the tier three timely notification and deny items beyond that statement + 60 days. If that same cardholder comes back after this dispute processes, and claims additional fraud on the same card dating back to 1/1/20, are we allowed under Reg E to re-evaluate that tier three application? Additionally, if the cardholder makes separate claims on two different days (consecutive days for example) is it correct that we may treat that as a single claim?