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#1875764 - 12/03/13 10:51 PM Reg E - what is our responsibility
Baker Offline
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Joined: Nov 2005
Posts: 777
Washington State
If we have a customer that comes to the bank and states that anything from XYZ vendor is not authorized what is required of the bank? Can you ask them to provide a date range? Otherwise, how far back would you go?

Additionally, if a customer comes in and states that XYZ has charged unauthorized transactions as well as authorized transactions but doesn't know which are which what is our responsibility? Can we say please review your statements and let us know?

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#1875767 - 12/03/13 10:56 PM Re: Reg E - what is our responsibility Baker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,944
Galveston, TX
1005(b)(1)(iii) Indicates why the consumer believes an error exists and includes to the extent possible the type, date, and amount of the error

Without those factors, it is not a claim of error.
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#1875772 - 12/03/13 11:08 PM Re: Reg E - what is our responsibility Baker
Baker Offline
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Joined: Nov 2005
Posts: 777
Washington State
To the "extent" possible seems to me that there is wiggle room for them not provide all three and still have a claim.

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#1875774 - 12/03/13 11:17 PM Re: Reg E - what is our responsibility Baker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,944
Galveston, TX
If they can't at least identify the individual transactions, I would argue differently. How can someone have a claim if they don't know what was or what was not supposedly unauthorized. Where would you start your investigation? Give them a copy of their statements and have them circle the ones they claim are unauthorized - that would meet the "extent possible" in my book.
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