The challenge, of course, is in dealing with the differences between 1005.6, which calls for reimbursing the customer for the oldest transactions when lack of authorization is involved, and 1005.11, which limits the consumer's ability to make error claims to the most recent transactions. And, of course, the vagaries of the other rules -- NACHA, Mastercard and Visa -- that may affect the final result.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8