Another scenario. Customer signs up for trial service of a product thru a merchant and charge is $100 per month. Customer cancels within 15 day trial period. Merchant charges $100 on 7/1, 8/1, 9/1 and 10/1. Statement cycle date is 15th of each month. Customer disputes on 10/1. The 7/1 $100 charge is more than 60 days after the statement which included the charge and is a recurring payment. Are we required to investigate and if so, can we withhold the first $50 since an access device was used? I realize the timing and disclosure provisions of 205.11 do not apply to the 7/1 disputed charge.