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#2218307 - 07/24/19 04:39 PM Prov Cr given to extend invest to 45/90 D-now late
scb2011 Offline
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TN
We give provisional credit to allow an extended investigation time to the 45/90 days. In one case the 45/90 days was incorrectly calculated and the final notice / provisional credit reversal (due to no error found) will be late. If we still provide the notice and provisional credit reversal within 3 days of the end of our investigation, are we allowed to reverse provisional credit? We realize we would be in violation of the timing, but does that cause the bank to not be allowed to reverse provisional credit?

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#2218313 - 07/24/19 05:18 PM Re: Prov Cr given to extend invest to 45/90 D-now late [Re: scb2011]
burkemi Offline
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Joined: Nov 2013
Posts: 425
Reg E says you must complete within 10 days. You may extend *up to* 45/90 to make the determination. If you have exceeded the 45/90 extended window then your extension has expired and this case has ended for better or for worse. No, you cannot revoke provisional credit. Remember, Reg E is super consumer friendly. Any questions pertaining to timing/crediting/finalizing....will generally be in the consumers' favor.
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#2218327 - 07/24/19 06:03 PM Re: Prov Cr given to extend invest to 45/90 D-now late [Re: scb2011]
John Burnett Offline
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I hate to agree, but I must. I hope it wasn't an expensive lesson learned.
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#2218579 - 07/26/19 08:29 PM Re: Prov Cr given to extend invest to 45/90 D-now late [Re: scb2011]
Andy_Z Offline
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You have a deadline, and when a decision is made, final is final. There is very little latitude in Reg E and you don't get more time because someone at the bank couldn't count the days or enter them correctly. If the consumer reported the loss after 2 business days, but says they meant to tell you sooner, they don't get credit for those days.

Someone should be using our BOL Claims Calendar for Reg E.
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