Correct. He passed the deadline for providing the written confirmation, so you aren't required to provide provisional credit under Reg. E (you have the option to do so, however). The deadline for completing your investigation would be 90 days from the date of the oral filing of the claim if the transactions were merchant transactions or transactions at ATMs located outside of U.S. jurisdiction.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8