We use Falcon for our debit cards. If they see suspicious transactions and make a call out to a customer and a customer tells them a charge was unauthorized, does that begin the clock ticking for us since they are our vendor? Reading the customer statements, they think they are talking to our fraud department.

The clock ticking for what rule or requirement?

Reg E investigation timelines. We require a written statement so we don't have to do provisional credit without it, but the overall 45 or 90 days--would it start from the day they talk to Falcon since they are calling on our behalf?

The time allowed for completing the investigation starts with the date the original complaint/claim is received, whether orally or in writing. To be totally accurate, it starts once any part of your bank has received information sufficient to identify the consumer and the account involved, why the consumer believes an error exists, and, to the extent possible, the type, date, and amount of the error. If you have held Falcon out to be your agent, it would start when Falcon is notified.

That was my opinion too, but I was getting push back from the business unit. Thank you John.

Did Falcon get sufficient information to get an error report? At the point the consumer is talking to Falcon, is the error amount known? It could be yes, it could be no. If it is just an authorization and not something that has posted at the point the customer is speaking to Falcon, the amount in error may not be known at the time Falcon took the call. I'm thinking of a $1.00 fuel auth that could post for a different amount or an internet purchase that was authorized but the merchant decides not to complete due to addr verification results or other reasons (in which case no error occurs).

Well....I can only go by the customer narrative on a written dispute statement and my issue is that it is perfectly clear in their narrative that they verbally identified(to Falcon) a transaction that was not theirs and thought they were talking to us.

I suppose for even a $1.00 authorization for fuel if it happened in California and you live in Florida and haven't ever been to California you would know was not yours.

Oh, I'm with you that the transaction is fraud. I'm just playing devil's advocate as to when the clock starts ticking. Depending on how quickly the cardholder reached Falcon, nothing may have posted yet so a key component of a reg e dispute (amount claimant feels is in error) may not be a known amount yet. It could be argued either way I guess, but I tend err in the favor of my cardholder.

I would think that since this third party vendor is directly interacting with your customers that all of this should have been addressed in the original vendor due diligence process.