1026.12 says a cardholder's liability is limited to $50 for unauthorized credit card transactions.

1026.13 defines a billing error to include unauthorized use and further defines a billing error notice as one that is received by the issuer within 60 days after statement transmittal.

The commentary to 1016.13(c) says 3). Relationship with §1026.12. The consumer's rights under the billing error provisions in §1026.13 are independent of the provisions set forth in §1026.12(b) and (c). (See comments 12(b)-4, 12(b)(3)-3, and 12(c)-1.)

I am a little lost. If a cardholder doesn't tell us about the unauthorized use for say six months after they received the first statement, are we obligated to give them the money back (less $50)? Or can we hold them to the notification timeline in 1026.13?

Bueller?

They have to notify you within 60 days.