Is it important that the customer written letter be completely free form? I was wondering if structuring the customer letter just a bit might help the branches do better interviews and get more of the info the back office needs? Most specifically, a broad header like 'Response from merchant to request for credit' etc.

What customer letter? All they have to do, if you require it, is confirm in writing. Most banks have specific forms available to a customer to do this.

If you want to see a sample, here's one and their may be more on the web:

https://www.greendot.com/greendot/cmsviews/GreenDot/assets/en-us/DisputeForm-en.pdf

Well, we are doing both. And requiring both. Oh boy. I was told our 3rd party who processes our merchant chargebacks won't process without the 'customer letter', which we are interpreting to mean the freeform letter.

Many 3rd parties do require the letter/form/whatever you want to call it. However, for Reg E errors you cannot require it from the customer. Are you actually turning customers away with valid Reg E errors if they won't fill out your form?

That is a concern. I am trying to document our work flow and then do my first Reg E audit.

I was told our 3rd party who processes our merchant chargebacks won't process without the 'customer letter'

1. Don't confuse processing charge backs with the rights and responsibilities required under Reg E. They are not related.

2. Find a new processor.

BTW - we were cited on our recent exam (FDIC) for requiring the customer signature on anything. This violates Reg E. Of course without the signature you are not required to give provisional credit, but you cannot require the signature.

It IS a little confusing, I must admit. I think at the point where the customer is being interviewed, though, there is no distinction in these processes being made by our branch folks.

I wouldn't expect your branches/front lines to be able to make the distinctions, tbh. I know here that would be way more effort than it is worth. Anytime something is unauthorized let the branches/front lines get as much info as they possibly can from the customer and send it to your department that handles the disputes to sort it out from there. If they are giving good customer service, typically the customer is willing to assist.

We have chosen to make this a branch responsibility with minimal back office resources devoted to it. I believe, with you, Gioia, this is not a recipe for success. Clearly. But thank you!

It is a specific recipe for disaster. With the recent UDAAP findings in this area, this is not an area to leave decentralized in the hands of untrained bank personnel.

One last question on this topic. Does anyone offer training on the VISA Operating Rules specifically? Does BOL?

I had always thought you could accept a Reg E error complaint orally, but are allowed to require a written complaint within 10 business days as long as you start your prompt investigation when the oral complaint is received, and inform the account holder that you are requiring the complaint in writing.

You wouldn't have to give provisional credit if you didn't receive the dispute in writing, but you cannot withhold the funds if you determine an error occurred.

Thank you for correcting me

Dolly, I did two sessions on VISA Rules and Reg E in October 2014. These are available in the Bankers Store

You can listen to a 10 minute excerpt of the presentations on VISA Advanced

VISA Basic

Thanks Brian.