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#2118940 - 02/21/17 04:10 PM Debit Card Dispute-no longer active customer
dac1 Offline
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Joined: Oct 2009
Posts: 38
A customer has come in and signed a debit card dispute for transactions on an account that has been closed for several months. We have identified the transaction liability going back to the first transactions over a year ago - but what are our provisional credit requirements since they no longer have an active account? Today is day #5 for Visa Rules but we do not have an account if we need to provide provisional credit while we are completing the investigation.

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eBanking / Technology
#2119135 - 02/22/17 06:58 PM Re: Debit Card Dispute-no longer active customer dac1
dac1 Offline
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Joined: Oct 2009
Posts: 38
To simplify question - what do you do if a FORMER customer disputes transactions? Investigation not completed in 5/10 day timeframe but they do not have account for provisional credit?

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#2119268 - 02/23/17 04:51 PM Re: Debit Card Dispute-no longer active customer dac1
David Dickinson Offline
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Central City, NE
Having an account is not a factor. You can always send them a check.
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#2119278 - 02/23/17 05:35 PM Re: Debit Card Dispute-no longer active customer dac1
BrianC Offline
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BrianC
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Illinois
I would also add that the provisional credit requirements only apply to those transactions which the consumer reported within 60 days of the transmittal of the periodic statement.

Section 1005.11 with the provisional credit and investigation process timeframe do not apply to the transactions for which you did not receive timely notice.
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#2119360 - 02/23/17 10:53 PM Re: Debit Card Dispute-no longer active customer dac1
MBTCompliance Offline
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Joined: Apr 2015
Posts: 346
If provisional credit is applicable on a significant amount based on timely notification, the former account holder is asked for and provides written confirmation within 10 business days, a check is mailed, but the investigation reveals the transaction was truly authorized and the customer does not return provisional credit?

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#2119363 - 02/23/17 11:02 PM Re: Debit Card Dispute-no longer active customer dac1
rlcarey Online
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rlcarey
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Galveston, TX
Sue them.
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#2119554 - 02/24/17 10:23 PM Re: Debit Card Dispute-no longer active customer dac1
Andy_Z Offline
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MBT, the question is not common. There isn't much you can do. Technically where Reg E says to pay provisional credit it refers to the account. Still, if you forced open an account the consumer gets full use of the funds, so you'd be in the same boat, except that you'd waive any low balance fees after the consumer complains to your regulator and you create more work.
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#2120128 - 03/01/17 09:32 PM Re: Debit Card Dispute-no longer active customer dac1
John Burnett Offline
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Cape Cod
And I am in the other camp that argues for reopening the account (or opening a new one) for the provisional credit and charging that account if you reverse the PC. At least you get a bona fide overdraft set up to chase. The concept of "provisional credit" doesn't blend well with "cashier's check."
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#2120133 - 03/01/17 09:45 PM Re: Debit Card Dispute-no longer active customer dac1
MBTCompliance Offline
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Agreed, John.

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