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#2240993 - 08/13/20 01:06 PM reg e 60 day timeline
reknab Offline
100 Club
Joined: Oct 2008
Posts: 234
not where I want to be
Customer reported 4 unauthorized ACH transactions. Two were within the 60 days, and two were not. We returned the two that were within the 60 days and gave the customer credit. We opened a reg e investigation for the two that were outside the 60 days, and did not give provisional credit, but did give credit when we were granted permission to return. Were we required to give provisional credit for the two items that were outside the 60 day timeline?

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eBanking / Technology
#2241002 - 08/13/20 03:46 PM Re: reg e 60 day timeline [Re: reknab]
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,730
Central City, NE
Here's a quick summary of the Error Resolution rules from our Reg E Training Manual. #3 answers your question.


E. Tying It All Together – Unauthorized Transactions §1005.6 vs. §1005.11:


1. Consumer Notice Within 60 Days (Statement Delivery) + Written Claim Within 10 Business Days

a. Provisional Credit IS Required

b. Follow §1005.11 Investigation Rules (Strict Timing Provisions)

c. Adhere to §1005.6 Liability Limits


2. Consumer Notice Within 60 Days (Statement Delivery) + No Written Claim

a. Provisional Credit NOT Required

b. Follow §1005.11 Investigation Rules (Strict Timing Provisions)

c. Adhere to §1005.6 Liability Limits


3. Consumer Notice NOT within 60 Days (Statement Delivery)

a. Provisional Credit NOT Required

b. Follow §1005.6 Investigation Rules (No Strict Timing Provisions)

c. Adhere to §1005.6 Liability Limits
_________________________
David Dickinson
http://www.bankerscompliance.com

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