In need of guidance on timing for processing billing error/dispute:

Our compliance person is stating that if we get a notice of billing error on the same day a customers billing cycles, that we have to remove the amount immediately upon notification or else we are violating the reg., since we are attempting to collect the debt that is now being disputed. The reg provides guidance when notification is received mid-cycle for resolving the error. Does that also allow time to ensure the amount is removed from their statement which does not necessarily happen the same day or next day after notification?

OFFICIAL INTERPRETATION TO 13(c)(2)
Paragraph 13(c)(2)
1. TIME FOR RESOLUTION. The phrase two complete billing cycles means two actual billing cycles occurring after receipt of the billing error notice, not a measure of time equal to two billing cycles. For example, if a creditor on a monthly billing cycle receives a billing error notice mid-cycle, it has the remainder of that cycle plus the next two full billing cycles to resolve the error.

Time for resolution and the consumer not responsible to make payment on the disputed amount are two different things.

As long as the customer is informed that they are not required to pay any disputed amount and the bank does not automatically debit the amount involved in the dispute from a consumer asset account (if billing error is submitted three business days prior to payment), there is no issue.

Most banks have the statement preprinted on the periodic statement stock.

We do have the billing error resolution statement on the back of the clients billing notice. Her hang up is that we cannot systemically remove the amount in dispute from the billing when it cycles the same day of the notification of the error and i am trying to tell her we have to be able to put the item in dispute status which can take two business days from the day of notification.Therefore we cannot remove the amount from the billing when it cycles the same day.

Tell her to go fry bigger fish. If you have told them they don't have to pay that amount, they don't have to pay regardless of whether you can act in that fast of a manner to have it reflect on the statement dropping the same day - geez..... What the heck are the odds anyway???

Seriously! Thank you!