How do you handle PIN-debit transactions disputed on a VISA debit card not processed by VISA? The zero liability won't apply, and the card is still in their possession. If the frist transaction is well more than 60 days ago, are you required to reimburse for the first one or the most recent one (which is the one made them realize the problem)? We have no charge-back rights since its PIN based.

Although you do not have obligations under VISA Zero Liability, the liability schedule of Reg E 1005.6 and your obligation to investigate under Reg E 1005.11 still apply.

Since the transactions did not involve an accepted access device, you can look to 1005.6(b)(3). It states that the customer is liable for any transactions that occur more than 60 days from the delivery of the statement date on which the first unauthorized charge appears. (i.e. the bank is liable for the early transactions and the customer for the later ones.)

If this is a clear case of a skimmed/counterfeit card, then you may as well reimburse the customer for the charges to which they are entitled and close the claim. However, if the charges are local and you want to take some time to research the claim you may. Since the customer did not provide timely notice (waiting more than 60 days from the delivery of the statement on which the first charge appeared) 1005.11(b) relieves you of the obligation to provide provisional credit or complete your investigation in 90 days. This will provide the opportunity to contact merchants directly and request video footage should you wish to conduct an investigation.