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#2197816 - 11/08/18 07:13 PM Reg E Dispute
Valley girl Offline
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Joined: Aug 2014
Posts: 394
TX
Dispute filed for unauthorized charges starting June 7, 2018 and continuing through September 28th. Total of $7,600.00 in charges. Did our 60 days from June 30th statement and reimbursed all charges through August 31st, a total of $1,660.00. Filed disputes with our processor on transactions over $25. Just got a pre-arb notice from two big Amazon purchases. Items were delivered to cardholders address and a name was given - it is our member's son. I called her and asked if she knew the name (didn't know it was son at that time).

My question is if she drops the disputes for any charges the son did, will I have to go back and reinvestigate the transactions in September that were not reviewed before because they fell outside the 60 days? I think we had two different frauds going on. I think the summer charges were just the kid, but I actually think her card was skimmed/hacked around September 9th and a real group of fraudsters got it (or the kid sold the number).

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eBanking / Technology
#2198029 - 11/12/18 04:10 PM Re: Reg E Dispute Valley girl
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You should investigate all charges. If you discover that all charges - even those beyond 60 days - are not legit, why not provide this to the customer? You don't have to, but you could win a loyal customer and get great P.R. from this. I see this as an opportunity to shine. If you find that they post 60 day transactions were from the son, you don't have to reimburse the customer.
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#2198110 - 11/13/18 06:05 PM Re: Reg E Dispute Valley girl
Valley girl Offline
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Joined: Aug 2014
Posts: 394
TX
Thank you for the response David. If I provide credit for the post 60-day transactions in this case, will I need to waive the post 60-day liability for all disputes in the future? I would feel that I am not being fair if I don't apply it to all disputes, especially if there is PR from this.

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#2198142 - 11/13/18 11:14 PM Re: Reg E Dispute Valley girl
David Dickinson Offline
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David Dickinson
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Posts: 18,762
Central City, NE
I don't think you are "all in" just because you did it for this one customer. There are no "fair deposit" regulations, so doing this for 1 customer doesn't mean you have to apply to it all customers going forward. I'm not suggesting this from a standpoint of fairness. I would want to understand the complete picture and know all of the facts. You might learn some things from the the errors that occurred beyond 60 days that could shed light on the ones prior to that. I'd also not want to have to reopen this case, if the customer comes back later with more questions/errors. However, that's my opinion.
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#2204411 - 01/30/19 03:17 PM Re: Reg E Dispute Valley girl
Susielou Offline
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Joined: Aug 2005
Posts: 362
Midwest
If a statement cuts on the 30th of month, how much time do we need to calculate for the mail getting to customer? When would we start counting the days for the 60th day?

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#2204423 - 01/30/19 03:36 PM Re: Reg E Dispute Valley girl
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
Look closely at 1005.6(b)(3). Unlike lending disclosures which have the 3 day period for mail to be considered received, Reg E has no such requirements. The 60 days starts on the day of the "transmittal" of the periodic statement which is the day you drop it in the mail.

"A consumer must report an unauthorized electronic fund transfer that appears on a periodic statement within 60 days of the financial institution's transmittal of the statement to avoid liability for subsequent transfers."
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#2204852 - 02/01/19 10:03 PM Re: Reg E Dispute Valley girl
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Or the date that you make it available to the depositor, in the case of "bank hold" statements and e-statements covered by E-SIGN.
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