We have a customer that just happened to finally review his DDA statement and is claiming ACH fraud from Jan-Feb 2012 and Debit Card Fraud starting in July 2012 through Jan 2013.

As both incidents occurred on the same DDA, are we on the hook for only the first 60 days to include the ACH losses only as the debit card fraud could have been prevented if the ACH losses were reported or the first 60 days of the ACH AND the first 60 days of the Debit card fraud starting in July 2012?

Any direction would be greatly appreciated. Thank you

I tend to take a conservative view on this (read: pro-consumer, since that's the bent of the EFTA and Reg E), and treat the ACH transactions and the debit card transactions as two separate fraud cases, regardless of how they might be reported by the consumer. I don't see, for instance, how the prompt reporting of the ACH fraud entries would have prevented the debit card problem.

Thanks John. It was the same entity doing the ACH, then resorting to the Debit Card trans. Will look for other avenues as cus story is as clear as mud.