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#2244612 - 10/26/20 06:19 PM Reg E Dispute- older than 60 days-NOT Unauthorized
M&M Offline
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Joined: Nov 2003
Posts: 527
Midwest
I'm second guessing myself and spending way too much time on rehashing this.

If I have a dispute that is NOT unauthorized, but is disputed outside of the 60 day timeframe, can we just deny the dispute and be done? Or do we have to accept and investigate it but just not follow the timeframe rules or provide PC?

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eBanking / Technology
#2244618 - 10/26/20 06:30 PM Re: Reg E Dispute- older than 60 days-NOT Unauthorized M&M
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
What is a "dispute that is NOT unauthorized"?
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#2244619 - 10/26/20 06:33 PM Re: Reg E Dispute- older than 60 days-NOT Unauthorized M&M
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 5,975
Illinois
Perhaps a dispute that falls under the category of an "incorrect EFT."

For example, I authorized $100.00, but I was charged $1,000.00. Since 1005.11 does not apply when notice is late, and the transaction is not considered unauthorized so 1005.6 liabilities are not triggered, then the institution would not have any obligation to investigate the claim and could deny it for late notice.
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#2244620 - 10/26/20 06:34 PM Re: Reg E Dispute- older than 60 days-NOT Unauthorized M&M
M&M Offline
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Joined: Nov 2003
Posts: 527
Midwest
Any of the other definitions of an "error" under Reg E other than unauthorized.

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#2244624 - 10/26/20 07:05 PM Re: Reg E Dispute- older than 60 days-NOT Unauthorized M&M
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
Thanks BrianC. That's exactly what I was trying to confirm. I've always provided guidance to that effect, but I saw a Reg E dispute workflow that incorrectly referenced this requirement, and it made me second guess myself. Appreciate your help.

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