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#2211585 - 04/18/19 10:03 PM Reg E Scenario...
mnbanker09 Offline
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Joined: Jan 2018
Posts: 128
Looking for guidance on a debit card dispute scenario, please.

Customer authorizes a transaction, contacts merchant who promises a refund. Refund doesn't come through. Is this a Reg E claim for 'Omission of an EFT from statement"? Or does not fall under Reg E as the transaction is authorized, and only a merchant dispute with Visa/MC?

Appreciate any feedback!

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#2211616 - 04/19/19 01:56 PM Re: Reg E Scenario... mnbanker09
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
Joined: Nov 2004
Posts: 505
Central Illinois
Doesn't sound like a Reg E error since the customer authorized the transaction.

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#2211627 - 04/19/19 02:56 PM Re: Reg E Scenario... mnbanker09
burkemi Offline
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Joined: Nov 2013
Posts: 552
This is generally considered to be covered by Reg E since the merchant promised a refund but failed to provide. Take a look at Brian C's reply in this Bankers Online thread.
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#2211628 - 04/19/19 02:57 PM Re: Reg E Scenario... mnbanker09
mnbanker09 Offline
100 Club
Joined: Jan 2018
Posts: 128
I did find the answer in another BOL post on Reg E, in case anyone else comes across this:

The question here as it pertains to Reg E, needs to focus on the refund being the disputed transaction. The transaction to make the purchase was authorized. There is no dispute there, but if a refund was promised and not delivered then that is an error.

Next, if she was in fact allowed to rescind the transaction and the company promised a refund which didn't come thru, that is a Reg E error. "An incorrect electronic fund transfer to or from the consumer's account;"

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#2211629 - 04/19/19 02:58 PM Re: Reg E Scenario... burkemi
mnbanker09 Offline
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Joined: Jan 2018
Posts: 128
Thank you, very helpful!

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