I have a question on the timing of the first deposit. As a credit union, when a member opens an account, they establish a share account with the PAR value of a share. Would that count as the "first deposit" according to Reg E? This opening deposit is made prior to the share draft being established and a card ordered.

(3) Extension of time periods. The time periods in paragraphs (c)(1) and (c)(2) of this section are extended as follows:

(i) The applicable time is 20 business days in place of 10 business days under paragraphs (c)(1) and (2) of this section if the notice of error involves an electronic fund transfer to or from the account within 30 days after the first deposit to the account was made.

That is the opening deposit of "an account" (the share account). It may not be the opening deposit of "the account" to or from which the EFT was made. The share account and any other account (i.e. checking, money market, etc.) are different accounts. The 30 days referred to in the regulation begins when the first deposit is made to the account in which the EFT occurred (or should have occurred).

Thank you rainman! Member opened checking account on same day as share account (May 4th). Fraudulent Cash App transactions posted to account June 9th. He's 18 and after lots of research, I found the Cash App recipient to be a local musician. Small amounts, so I can't dispute through our processor. We don't offer instant issue so the card was only active for 15 days or so. I was hoping for a little more investigative time to do some social media review.