If you have branched in multiple cities, can you have multiple contact numbers and address to write in the even of an unauthorized error?
Thanks.

Sure. That would be OK under the regulation. But I suggest you shy away from prohibiting a customer from filing at a designated place that his account isn't "assigned" to.

If your goal is to bring the responsibility for handling these requests closer to the customer, weigh that goal against the need to have multiple groups of persons trained in the handling of these requests. It would be a good idea to keep your actual error resolution follow-up and investigation team centrally located, but you will want to ensure that all requests are forwarded there immediately so you don't lose time "in transit."

That 10 days goes by awfully quickly if some of it is wasted getting a case forwarded to your back room.

I agree with John. You want to make it easy for the consumer and you must protect your bank. Train the branches on what you want done, telephone, form & fax or interoffice, etc. Looking at the OSC, at §205.6 A financial institution is considered to have received notice for purposes of limiting the consumer's liability if notice is given in a reasonable manner, even if the consumer notifies the institution but uses an address or telephone number other than the one specified by the institution.

So create these outlets and train, train, train. I have seen the central area get the claim on day 10 and be immediately forced to provide provisional credit upon opening the file.

re: ATM PIN based fraud claims

Does anyone have guidelines for denial? I'm clear on liability based on timeframes, but what about cases where the story changes, card/PIN used by household member-with or w/o prior auth, was drunk-not sure what happened, left card in ATM during trans, etc.?

Too many scenarios there to count. Did the customer do it, benefit from it or authorize it (even by giving the card and PIN to someone who exceeded the authority given to them)? This is the root (or route if you follow my analogy), though not necessarily the final destination. Each claim has its facts and those influence the answers.

I often refer folks to OCC AL 2001-9 for some excellent investigative questions and processes.

Thanks for the info Andy Z. I appreciate your help. The OCC AL is exactly what I was looking for.

Just so I understand completely, the burden of proof is on the financial institution and short of photographic evidence or confession, we have to pay the claim?

The point of the investigation is to use the info to solicit confession or withdrawal of the claim?

The cases I get are lost/stolen ATM/Debit cards used for pin-based withdrawals/transactions.

You don't necessarily have to prove that the customer did it, authorized it or benefited from it. While that would greatly help, just ask yourself if you have a defendable case.

The ATM was frequented by the customer.
It was done at a time when he wasn't at work.
His story changed and on the 5 transactions, we saw him in 2, then he said it was the other 3 he meant.

None of these facts is conclusive, but combined they could be justification for denial, in my opinion. Opinions will vary. I think this is reasonable. Seeing in the file that "my gut tells me he did this", doesn't cut it, especially if the denial rate of claims seems unreasonable.

Glad the reference material helped.