I am having trouble with the language in 1005.11(b)(1)(iii) which states: "Indicates why the consumer believes an error exists and includes to the extent possible the type, date, and amount of the error..."

My problem specifically is "to the extent possible". I am trying to wrap my head around what that means in terms of being able to complete a Reg-E claim. If the customer states they were charged the incorrect amount, but never clarifies what they should have been charged, how do we make the customer whole?

I can identify the customer and the account, but can being charged a wrong amount be the "why a consumer believes an error exists" when they don't provide any additional information, like what they were expecting to be charged? That seems to me to not meet the "extent possible" part if that sentence.

Thoughts?

An incorrect amount is included in the definition of an error under Regulation E:

(1) Types of transfers or inquiries covered. The term “error” means:

(ii) An incorrect electronic fund transfer to or from the consumer's account

The challenge with this is that Regulation E is a very consumer friendly regulation. Therefore, I would work to get clarification from the customer so that you can proceed with your investigation. That said, if they aren't giving you anything to go on (i.e. not telling you what amount the charge should have been), I'm not sure how you could complete an investigation and you may have an out through the section you quoted in 1005.11(b)(1)(iii).

As Reg E disputes are often highly scrutinized by auditors and examiners, if you are unable to conduct the investigation due to a lack of information, make sure you clearly document your file so that the explanation is clear.

Yes, we opened a claim due to the customer stating the transaction was for an incorrect amount. He has not returned any calls to further clarify what the correct amount should be.

My thought was exactly that: possibly denying the claim due to not being able to determine what the dispute is for, in other words: what would it take to make the customer whole? Otherwise I see my only option being to give the customer credit for the full transaction.

Although I don't know the exact amount the customer is disputing, I do know he is not disputing the entire transaction, so giving credit for the entire transaction doesn't seem like the best option either - plus it is a loss for the bank (which I know figures into Reg-E at exactly 0%).