A customer engaged in purchases with an online merchant, various amounts where the transactions were authorized.

In October 2019, an amount was charged to the customer's account from this same merchant, and was refunded weeks later. A second charge in the same amount posted in March 2020, and then again one year later (March 2021). Customer contacted the merchant after the 2021 transaction posted, and said they would refund this charge, and they did. However would not refund the charge from a year prior. Customer claims not authorized and did not sign up for the subscription. Retrieval request for authorization was not successful as part of our investigation.

Based on the timeline...is the date of the first error considered October 2019, as the customer claims she didn't authorize any of those charges...or not until March 2020? Trying to determine bank liability.

My initial impression is that the 2019 transaction isn't involved since the customer has already been reimbursed for it. Under Regulation E, the 2020 transaction could be the subject of the customer's claim, since the customer is claiming it was not authorized, and has not been paid back. If you determine from your investigation, that the 2020 transaction was not authorized, you will have to refund the customer's account for it. The customer would be responsible for the 2021 transaction if the merchant had not already refunded it.

Thank you!