Skip to content
BOL Conferences
Thread Options
#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?

Return to Top
eBanking / Technology
#1433070 - 08/24/10 10:45 AM Re: Regarding Reg E CAKE
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Technically - Yes
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1437999 - 09/02/10 01:29 PM Re: Regarding Reg E rlcarey
reknab Offline
Gold Star
Joined: Oct 2008
Posts: 281
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.

Return to Top
#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.

Return to Top
#1438363 - 09/02/10 06:00 PM Re: Regarding Reg E Dazed Auditor
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
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!
www.tcaregs.com

Return to Top

Moderator:  Andy_Z