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#2213844 - 05/16/19 10:07 PM Reg E disputes not investigated
scb2011 Offline
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Joined: Mar 2011
Posts: 255
TN
Our bank has a cut off for Reg E investigations. Single amounts $25 or less are not investigated and are given credit immediately. The commentary to section 11 states that if no investigation is conducted we must still comply with section 11. If we "investigate" within 10 days we can tell the customer orally or in writing. Does telling the customer we will give them the $ at the time they make the dispute satisfaction of our requirements for disputes? i.e. no written notice is required, is that correct?

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#2213862 - 05/17/19 12:58 PM Re: Reg E disputes not investigated scb2011
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,629
Originally Posted By scb2011
Does telling the customer we will give them the $ at the time they make the dispute satisfaction of our requirements for disputes? i.e. no written notice is required, is that correct?


Regulation E says that you must report the results to the consumer within three business days after completing your investigation. If you complete your investigation within the first 10 days (which it sounds like you are completing it and making it final at the time of dispute), then you need to tell the customer the results of your investigation. In other words, you need to tell them (orally or in writing) that the money they are getting is final and the investigation is closed. If you do that, no further action is needed.

The only time section 11 requires a written notice (i.e. oral notice is not an option) for when you notify your customer is when you discover there was not an error or a different error occurred. Said another way, if you are agreeing with the customer and giving them final credit, then oral notification is sufficient. That said, financial institutions need to ensure that oral notifications are sufficiently document and, for this reason, many just choose to provide written notice even if an oral notification is acceptable under Regulation E.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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