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#2202700 - 01/11/19 01:57 PM Reg E Dispute Timeframe Question
mdog76 Offline
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Joined: Jan 2007
Posts: 645
I'm new to the world of Reg E and disputes and have a question:

When does the 10 day clock for provisional credit begin when at the time of the dispute the only charge on the account in the pre-authorized amount and not the actual charge i.e. paying for gas at the pump. Does the clock begin when the dispute is made or when the actual charge hits the account?

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eBanking / Technology
#2202701 - 01/11/19 02:13 PM Re: Reg E Dispute Timeframe Question mdog76
Adam Witmer Offline
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Great question, mdog76. I'm actually working on a comprehensive article on this topic that I will publish within the next few months.

In short, the way I see it is that "preauthorized amounts" are not a "transfer from a consumer's account" so the clock doesn't start until the transaction actually posts. Technically, you can also argue that the customer can't make a dispute until the charge actually hits the account, so the clock can't start until then either. That said, Reg E is VERY consumer friendly so it is important to dot your "i's" and cross your "t's" with your team who is managing this process.
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#2202812 - 01/12/19 01:17 AM Re: Reg E Dispute Timeframe Question mdog76
David Dickinson Offline
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I agree. The account must have a debit (transaction post) before you can have a claim of an unauthorized transaction.
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#2203165 - 01/16/19 07:41 PM Re: Reg E Dispute Timeframe Question mdog76
John Burnett Offline
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I'll harmonize with that tune.
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#2203205 - 01/16/19 09:31 PM Re: Reg E Dispute Timeframe Question mdog76
burkemi Offline
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Joined: Nov 2013
Posts: 528
We have been accused of taking unnecessary steps here. When we receive one of these "disputes," we watch the account until the transaction posts (in which case we provide provisional credit and pursue any chargeback rights we may have) or until the preauthorization expires (in which case we notify the customer that there have been no transactions posted to the account and we advise them to keep an eye on their account). All that said, I agree with what everyone else has stated - no posted transaction, no timeframes. When these transactions post and we begin our investigation, we consider that to be day 1.
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#2203209 - 01/16/19 09:40 PM Re: Reg E Dispute Timeframe Question mdog76
John Burnett Offline
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Cape Cod
Above and beyond the call of duty, burkemi. I do hope that the task force working on improved payment times comes up with a way the credit card infrastructure can be modernized to go real time like the ATM infrastructure so the posting delays can be eliminated.
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#2203510 - 01/20/19 09:08 PM Re: Reg E Dispute Timeframe Question mdog76
Andy_Z Offline
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burkemi, part of this capability will depend on the volume of these claims and systems capabilities. This could be expensive.

I recall some banks telling me, as an example, they'd reduce military loan rates to 0% as a way to show support to military borrowers. That doesn't work for a military bank where 90% of your loans are to the military. (These were not SCRA conditions, just support of the military.)
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