In reviewing our financial institution's procedures for disputing debit card and credit card transactions, we are requiring that the customer attempts to resolve this issue with a merchant themselves prior to filing a dispute. I see nothing in Reg E/Reg Z that indicates that consumers are required to research and attempt to resolve with another merchant prior to contacting us and want to remove this verbiage from the procedures. Can we require a customer to complete due diligence prior to disputing a transaction?

Customers are NEVER required to research. Requiring them to do so can cause some very hefty finds - both Reg E and UDAAP issues. I know a bank in KY that was fined $100,000 for similar practices.

Ditto Skittles. You can ASK, but you can not require.

I agree- if it's Reg E or Reg Z covered transaction- Unauthorized or Error- but there are many claims that some many call a "Dispute" that are not covered by the regulations. It's those types that it would make sense for the cardholder to try to resolve with the merchant, first. For Visa/MC chargeback rights, we would need the information from the cardholder- but, again, these are "Disputes" not covered by Reg E or Reg Z.

What disputes aren't covered by Reg E/Z? Is it buyer's remorse?

Please note I am not a guru- but have been around for awhile.
Merchandise Never Received (though some may say this is a merchant error and under Reg E)
Cancelled Recurring Charge
Incorrect Merchandise Received (though some may say this is a merchant error and under Reg E)
Reservation Cancelled
Not satisfied with purchase/ quality of good issue (this is not Reg E, but IS under Reg Z for credit cards )- if over 50.00, transaction occurred in the same state as current designated cardholder address, or, if not within the same state- then within 100 miles from that address. The cardholder must have made a good faith attempt to resolve the dispute with the person honoring the credit card.

Back to the original question:
§1005.6(b)(5):
Notice to a financial institution is given when a consumer takes steps reasonably necessary to provide the institution with the pertinent information, whether or not a particular employee or agent of the institution actually receives the information.

§1005.11(b)(1):
[i]A financial institution shall comply with the requirements of this section with respect to any oral or written notice of error from the consumer that:
1. Is received within 60 days of statement.
2. Identifies the customer (name & account #)
3. Indicates why they believe an error occurred.

Telling a customer they have to go back to a merchant, sign a statement, etc. is a violation of Reg E. You can't take people's rights away from them.