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#2119611 - 02/27/17 04:20 PM Re: Customer Liability and Reg-E 60 day timeframe BrianC
fmissle Offline
Diamond Poster
Joined: Jul 2007
Posts: 1,025
Pac NW
Originally Posted By BrianC
BOL's very own Andy Zavonia.

https://www.bankersonline.com/tools/42546

I used this recently for a year long string of various Reg E claims and it was amazing.

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Operations Compliance
#2143076 - 08/22/17 05:38 PM Re: Customer Liability and Reg-E 60 day timeframe DingoJ
ILMF2016 Offline
New Poster
Joined: Apr 2016
Posts: 15
Need Assistance....

Member notified the credit union on 8/14/17 that the following unauthorized debit card transactions occurred (online purchases – no pin) and is in possession of his card. The member discovered the August transactions on 8/13/17 and then searched his account and found one back in March that was to the same company that was never authorized.

• 3/17 $47.87
• 8/02 $114.48
• 8/02 $245.59
• 8/02 $47.81

I am struggling because Reg E 1005.6 places unlimited liability on the customer for transactions that take place more than 60 days after the statement date on which the first charge appears. Since the member discovered the March unauthorized transaction in August along with the other August unauthorized transactions, is the member liability for the transactions in August?

If the member is liable for the August transactions, adding to that confusion is that August unauthorized transactions do have chargeback rights so why wouldn't we process those transactions?

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#2143081 - 08/22/17 06:02 PM Re: Customer Liability and Reg-E 60 day timeframe DingoJ
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A strict reading of the §1005.6 rules starts your counting of days with the day the statement was provided that included the March 17 transaction. For example, assuming that you determine that all four transactions were unauthorized, and assuming the statement was sent on March 31, count out 60 days from then (May 30). The member gets reimbursed for the March transaction, but is responsible for the August transactions.

If you charge back the August transactions, you will also have to credit the member for those chargebacks, but you'd be doing it under the Mastercard or Visa rules, not Regulation E. Then, if the merchant successfully represents the transactions, you can take the funds back from the member (because you're not working with Reg E now).
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BankersOnline.com
Fighting for Compliance since 1976
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#2143151 - 08/22/17 09:40 PM Re: Customer Liability and Reg-E 60 day timeframe DingoJ
ILMF2016 Offline
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Joined: Apr 2016
Posts: 15
Thank you John.

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#2156482 - 12/07/17 06:33 PM Re: Customer Liability and Reg-E 60 day timeframe DingoJ
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Our Deposit Operations area sent us Andy's worksheet and wants to begin using it. Since the worksheet was created a few years ago the holiday's have not been updated. Is there an easy way to do that so the number of days calculate correctly?

Thank you!
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#2156676 - 12/08/17 08:46 PM Re: Customer Liability and Reg-E 60 day timeframe DingoJ
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If you have downloaded the Excel spreadsheet from https://www.bankersonline.com/tools/42546 you can open the Cal & Claim tab and enter the holidays in the yellow area in column J. That allows you to reach back to a prior year if you're looking at old transactions. I suggest starting in J6 with Labor Day of the prior year, and loading in each of the holidays through Christmas of the current year.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2187306 - 07/30/18 04:58 PM Re: Customer Liability and Reg-E 60 day timeframe DingoJ
Monster Offline
Platinum Poster
Joined: Sep 2015
Posts: 502
I am unable to open the tool, does anyone else have this problem? "Certificate of Error - The application experienced an internal error loading the SSL libraries."

May or may not be related - but the majority of the time the hyperlinks referencing previous threads all give me the 404 message. I assume this may have something to do with an update to BOL since they are usually older threads... has anyone figured out our to make them work? Rlcarey's post above is a good example:

Brian's answer here might be of assistance:

http://www.bankersonline.com/operations/guru2011/gurus_op061311e.html

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