Do be careful, however. The EFT Act is subchapter VI of 15 U.S.C. Chapter 41 (Consumer Credit Protection). ECOA is subchapter IV of Chapter 41. Under ECOA §1691, it is unlawful to discriminate against any applicant, with respect to any aspect of a credit transaction "because the applicant has in good faith exercised any right under this chapter."
So, while it may be fine to deny another debit card or even close a consumer's deposit account(s) for repeated error claims under Regulation E, you can't call his loan or refuse him credit based on those error claims, unless you can back up a claim that he made them not in good faith.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8