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#1780880 - 01/29/13 07:57 PM Reg E - "series of related unauthorized transfers"
Compli(cated) Offline
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Joined: Mar 2011
Posts: 185
Wisconsin
I'm looking for some insight as to what constitutes a "series of related unauthorized transfers" under reg E. It appears that the customer may know who actually used their card for several transactions - I know this does not affect limitation on their liability but would like to know if the transactions need to be treated as a "series" for the calculation of liability amounts.
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#1780913 - 01/29/13 08:27 PM Re: Reg E - "series of related unauthorized transfers" Compli(cated)
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,463
Illinois
A series is any claim made at the same time of more than 1 transaction.

You can't say to the customer...well the first set of transactions was at merchant A so we'll treat those as one claim and assign $50 in liability to those, and this next set is at merchant B so we'll treat that as another claim and assign an additional $50 of liability.

You must go by when the cardholder learned of the theft of the access device and when they reported it to you.


If you haven't already, chcek out Andy Zavoina's upcoming webinar on Reg E which will be on Feb 19th. He'll provide some useful tools to for liability calculations and claim management.

http://calendar.bollearningconnect.com/main.php?view=event&eventid=1355932672493
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#1780936 - 01/29/13 08:50 PM Re: Reg E - "series of related unauthorized transfers" Compli(cated)
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Wisconsin
Thank you for your response Brian. If I understand correctly, you're saying the thing that makes it a "series" is the time of reporting by customer and really has nothing to do with transactions themselves.

I guess it makes sense. What was throwing me off, I think, was the "related" part; I don't see what purpose the word serves in that sentence, if the explanation is just that simple.
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#1780949 - 01/29/13 09:09 PM Re: Reg E - "series of related unauthorized transfers" Compli(cated)
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,463
Illinois
In this case what makes the transactions "related" is that they all were processed using the same debit card.

Now if I were to have unauthorized charges on my card and my wife also had unauthorized charges on hers, although we have a joint account, we would have two seperate series of unauthorized transactions even though we made our claims at the same time.
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#1780951 - 01/29/13 09:13 PM Re: Reg E - "series of related unauthorized transfers" Compli(cated)
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Joined: Mar 2011
Posts: 185
Wisconsin
I'm not doubting your answer, but could you point to a source of this information?
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#1780975 - 01/29/13 09:40 PM Re: Reg E - "series of related unauthorized transfers" Compli(cated)
BrianC Offline
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BrianC
Joined: Nov 2004
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Illinois
This is simply my understanding of the language/verbiage used in the regulation.

Using Webster's --- "Definition of SERIES
1a : a number of things or events of the same class coming one after another in spatial or temporal succession "

"Definition of RELATED
1: connected by reason of an established or discoverable relation"

You have transactions all on the same debit card and it sounds like the same person. IMHO, each transaction would constitute and "event of the same class..."

Since 1005.6(b)(1-2) refers to calculating liability based on the theft of an access device, I believe that it is reasonable to determine that a common access device is what would make a series of transactions related.
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#1780990 - 01/29/13 09:55 PM Re: Reg E - "series of related unauthorized transfers" Compli(cated)
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Joined: Mar 2011
Posts: 185
Wisconsin
Thank you again Brian, just wanted to know that I wasn't missing something in Reg E!
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