Reg E requires that if you are unable to resolve a dispute within 10 days of notification you are required to provide provisional credit. What should a bank do if the customer closes their account prior to providing the provisional credit?

You still must provide the provisional credit. If the account is closed, you must either reopen it or open another account for this purpose.

If I understand this correctly, a consumer can dispute an unauthorized eft from 2005, even if there account was closed in 2006. I know this is an extreme example, but relevant nonetheless.

What we are not required to follow is the timing of investigation and provisional credit requirements.

Is that correct?

Correct. And the example is no so extreme as you might think. It happens.

There is no statute of limitations on the claim based on when the withdrawal happened. The timeline does afford you the ability to use as much time as is needed to investigate the claim. That is, there is no provisional credit or 10 day time period hanging over you. I urge bankers to be reasonable and not drag their feet, but I can only imagine the "are you kidding me me" comments that would come from a request of old receipts and video.

Fortunately we don't see these too often.