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#2103396 - 10/18/16 02:35 PM Reg E Dispute
jonv Offline
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Joined: Jul 2009
Posts: 104
Not sure why I'm getting hung up on this, but would appreciate some advice. I'll try to keep this short!

On 10/13/16, we had a customer that has disputed over $3,000 in unauthorized debit transactions from 9/26/16 to 10/5/16. The customer has completed an affidavit that these are not authorized. The transactions were processed by our system due to fraudulent check deposits that the customer claims they did not do (i.e. mobile deposits). The fraudulent checks have since been returned and the account is overdrawn nearly $3,000.

The customer now has a legitimate insurance payment for $300 that we need to determine whether to pay or return. Since we are actively investigating this claim (i.e. within our 10 day investigation period), do we have to pay this item? As a sidebar, we feel the customer is not telling us the truth but have not been able to completely determine this (we are getting police involved).


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#2103401 - 10/18/16 02:52 PM Re: Reg E Dispute jonv
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
Of course you will research the source (phone) of the mobile deposits as part of your investigation. Have you provided provisional credit? If the account is legitimately overdrawn with the provisional credit included, of course you can return the $300 insurance payment.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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