Scenario: Cardholder submitted Visa Debit EFT dispute for 2 small claims at local Circle K. I'm not an expert on PIN vs signature transactions but bank denied disputes solely because "No Invalid PIN attempts made with customer card." Is this enough of an "investigation" that would allow the bank to deny the dispute claim.

Thanks.

Absolutely not.

Since the commentary to 1005.6 notes that a customer can write their PIN on their card and still be protected by Reg E, denying a claim solely because the PIN was used does not provide adequate evidence for us to conclude that the customer performed the transaction.

The poster child for this was First California Bank and its third party vendor that serviced Reg E claims.

https://www.fdic.gov/news/news/press/2013/pr13045.html

They denied transactions because a PIN was used which resulted in civil money penalties and customer restitution.

"any consumer who, between April 8, 2011 and November 30, 2012, submitted a claim for resolution of a dispute involving a PIN-based transaction or transaction exceeding $500 and that claim was either abandoned by the consumer or denied by Achieve..."