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#2071340 - 03/29/16 03:13 PM Third party processing disputes
CARM9 Offline
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Joined: Feb 2011
Posts: 112
I visited a Credit Union (CU) that uses VISA to process their Reg. E disputes and was told that the member cannot dispute a transaction with the CU directly, they have to call VISA and the date of notification is when VISA keys the members dispute into their electronic system. Seems like a violation of the notification requirements since the Reg. states it can be oral or in writing to the Financial Institution. Am I missing a citation in the Reg?

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#2071513 - 03/29/16 10:00 PM Re: Third party processing disputes CARM9
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,204
Illinois
Interesting little note in the staff interpretations to 1005.11(b)(1).

"Notice at particular phone number or address. A financial institution may require the consumer to give notice only at the telephone number or address disclosed by the institution, provided the institution maintains reasonable procedures to refer the consumer to the specified telephone number or address if the consumer attempts to give notice to the institution in a different manner."

Look at the Credit Unions EFT Disclosure. If in the error resolution section they direct the consumer to contact VISA directly using VISA's phone number and address and staff is properly trained to refer the customers to the VISA number or address, then they are in compliance.
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#2071672 - 03/30/16 06:47 PM Re: Third party processing disputes BrianC
CARM9 Offline
100 Club
Joined: Feb 2011
Posts: 112
Thank you Brian! smile

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