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#2216391 - 06/25/19 03:22 PM Reg E - interest as well?
HappyGilmore Offline
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Pulling people out of the ditc...
Customer files an unauthorized claim, bank determines it is unauthorized and reimburses the customer the amount of claim. Is there a regulatory requirement to calculate back interest if an interest bearing account? if so, from date of claim? or date of transaction?
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#2216392 - 06/25/19 03:37 PM Re: Reg E - interest as well? HappyGilmore
CompliantOkie Offline
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OOOOOOklahoma
The Reg states the bank is to credit back the transaction, any fees incurred because of the transaction and interest. We calculate the balance had the unauth transaction not occurred and apply interest accordingly from the date of the transaction. The goal is to make the customer whole as if the transaction had never occurred.

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#2216398 - 06/25/19 04:09 PM Re: Reg E - interest as well? HappyGilmore
BrianC Online
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Illinois
Staff interpretations to 1005.11(c)

Correction of an error. If the financial institution determines an error occurred, within either the 10-day or 45-day period, it must correct the error (subject to the liability provisions of §§ 1005.6(a) and (b)) including, where applicable, the crediting of interest and the refunding of any fees imposed by the institution. In a combined credit/EFT transaction, for example, the institution must refund any finance charges incurred as a result of the error. The institution need not refund fees that would have been imposed whether or not the error occurred.
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#2216409 - 06/25/19 05:52 PM Re: Reg E - interest as well? HappyGilmore
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
thanks to both of you...

Okie - is that a manual calculation?
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#2216531 - 06/26/19 04:47 PM Re: Reg E - interest as well? HappyGilmore
CompliantOkie Offline
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OOOOOOklahoma
Unfortunately ours is manually calculated. Our dispute mgmt. software does not include interest calculation. We built a spreadsheet for the card team to use.

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