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#1433019 - 08/23/10 10:36 PM Regarding Reg E
CAKE Offline
Junior Member
Joined: Apr 2005
Posts: 25
Regarding Regulation E - if a customer notifies us two years after an unauthorized transaction occurs, would we still be liable for the first 60 days of transactions?

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eBanking / Technology
#1433070 - 08/24/10 10:45 AM Re: Regarding Reg E CAKE
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 77,294
Galveston, TX
Technically - Yes
The opinions expressed here should not be construed to be those of my employer:

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#1437999 - 09/02/10 01:29 PM Re: Regarding Reg E rlcarey
reknab Offline
100 Club
Joined: Oct 2008
Posts: 247
not where I want to be
Two years??? We are way out of compliance then! I thought the customer had 60 days from the date of the statement that the unauthorized transaction appeared on.

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#1438087 - 09/02/10 02:52 PM Re: Regarding Reg E reknab
Dazed Auditor Offline
Platinum Poster
Dazed Auditor
Joined: Apr 2005
Posts: 637
Acceptance, USA America
You may want to revisit 205.6 and 205.11 and the definitions of unauthorized transactions and errors.
I overstand.

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#1438363 - 09/02/10 06:00 PM Re: Regarding Reg E Dazed Auditor
BrianC Online
Power Poster
Joined: Nov 2004
Posts: 6,019
Reg E provides that a customer's liability can be unlimited for transactions AFTER 60 calanders days from the date the FIRST transaction appeared on the statement. There is no provision that allows you to deny the claim based solely on late notice. You are, however, relieved from the requirements for provisional credit and 45/90 day investigation timeframes.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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