We have a customer that just now disputed an electronic transfer from 2011. I know we are not held to the investigation time frames or provisional crediting requirements under 1005.11, but 1005.6 liability rules still apply. My question is, this customer has had numerous NSF fees since the time of the disputed transaction – if we find that the transaction was indeed unauthorized, do we have to refund all the NSF fees that resulted from the disputed transaction from 2011 up until now, or just the NSF fees that occurred within 60 days of the statement showing the unauthorized transaction? If the customer is liable for all transactions after 60 days because they did not inform us on time, then are they also liable for the NSF fees after 60 days? (The suspicion is that the customer is only filing a dispute in order to get NSF fees refunded.)

Before refunding a dime, the first step is it do you best to investigate the claim. If you determine that you will reimburse the customer, you only need rebate fees that would not have occurred if the disputed charge had not posted. It may take some time, but go back to the 2011 charge and start with the account balance just before the charge posted. Then add & subtract all account activity. Any fees that would not have occurred, don't deduct. If any items would have created overdrafts even without the disputed charge posting, then those fees do not have to be rebated. Also, on any disputed chatges for which the customer is liable, fees resulting from those charges need not be rebated.

The next decision is whether you want to keep your debit card (assuming this was DC created) in this person's possession. If they acted irresponsibly and have caused you to take a loss, I'd consider not reissuing. Going back more than a year is a PITA and more costly than a claim from last week.

I've seen more than one claim denied and the customer says "oh, yes that was me. Sorry" when you show them an ATM photo with them in it.