We have an individual account and the sole owner is now deceased. Her son does not have access to the account and has not seen statements, but has called and said that his nieces have used the account in the past without authorization and that they may still be doing this. The account was restricted when we learned of the death, but there were a handful of card transactions that occurred subsequent to her death, but prior to us learning of the death.

I know that Reg E states that someone can make a claim on behalf of the consumer, but the son does not yet have letters of testamentary or know any specifics of transactions on the account. Is he able to make this general claim? Should we file a dispute for the transactions after death or should we wait until he brings in his paperwork? If we wait and he does bring in the letters of testamentary, does he have a valid claim? How do we know for sure that his mom didn't authorize her granddaughters to make transactions on the account?

I would wait until an executor is appointed. Since mom has passed away, they would not really be acting on the consumer' behalf. They need to now be acting on behalf of the estate.

Any authorization given by mom died with her.

2. Notice by third party. Notice to a financial institution by a person acting on the consumer's behalf is considered valid under this section

Thank you!