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#2253942 - 05/14/21 05:56 PM Reg E Dispute- Lack of information
Eagle06 Offline
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A customer provided an error notice for which further information is needed before we can begin our investigation. Based on the information we currently have, the transaction may have been authorized, but we would need to talk to the customer in order to determine that. Mastercard will not open a dispute based on the current info. We have made several phone calls and left voicemail but the customer has not responded. We are on day 10 of the provisional credit window. Must we provide provisional credit and try to move forward with an investigation in hopes that the customer will eventually respond, or can we deny the claim based on insufficient information?

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#2253944 - 05/14/21 06:13 PM Re: Reg E Dispute- Lack of information Eagle06
Skittles Offline
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The only information the customer is required to give the bank is enough to identify the transaction being disputed. Have you requested written confirmation?
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#2253945 - 05/14/21 06:27 PM Re: Reg E Dispute- Lack of information Eagle06
Eagle06 Offline
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They have provided the notice in writing. Basically, the customer incurred two charges from a hotel. One was authorized but the second was not supposed to be charged until a wedding took place. The wedding was cancelled and the customer is disputing the second charge. We need additional information from the customer in order to begin our investigation.

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#2253946 - 05/14/21 06:35 PM Re: Reg E Dispute- Lack of information Eagle06
Skittles Offline
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Since you have received your required written notification then you have no choice but the provide provisional credit. Maybe Brian will add his expertise to this thread.
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#2253948 - 05/14/21 06:38 PM Re: Reg E Dispute- Lack of information Skittles
Eagle06 Offline
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Thanks. I was afraid of that.

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#2253950 - 05/14/21 06:44 PM Re: Reg E Dispute- Lack of information Eagle06
Skittles Offline
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As I told someone yesterday when doing a very high level of deposit compliance training - Reg E is BY FAR the most consumer friendly regulation and is my least favorite (not that I particularly have a favorite).
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#2253951 - 05/14/21 06:45 PM Re: Reg E Dispute- Lack of information Skittles
Eagle06 Offline
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That's exactly what I told the ops person!

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#2253952 - 05/14/21 06:56 PM Re: Reg E Dispute- Lack of information Eagle06
BrianC Offline
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Brian's ears were ringing.

1005.11(b) requires that the customer provide their name, account number and why they believe an error exists. Based on your description of the sequence of events, the customer is claiming that they revoked the authorization to charge the card when cancelling the wedding.

1005.11(a) defines an unauthorized or incorrect EFT as an error. We cannot deny a claim solely on the basis of the customer not providing enough evidence to give us chargeback rights. Reg E doesn't care whether we can use the chargeback process as a means of conducting our investigation.

It is entirely possible that the customer was charged a cancellation fee for which they do not want to be held responsible. If faced with this claim on my desk I would do two things. 1) Review the merchant's website to see if they have any default agreements posted on the site that I can use to demonstrate why the charge was authorized and not an error. 2) Call the merchant myself to see if I can find more information about the second charge if there is nothing on the website. Merchants want to avoid chargebacks as much as issuing banks do and they may be willing to provide some details about their side of the dispute.
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#2253955 - 05/14/21 07:07 PM Re: Reg E Dispute- Lack of information BrianC
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Thank you so much, Brian!

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