It has been my experience that most financial institutions request a consumer sign a specific form (vendor developed; card processing developed; or internally developed) - what I would consider 'industry standard'. I have a client who was cited by the FDIC (who said 'all' regulatory agencies are citing this as an issue) for 'requiring the use of a particular form'. Regulation E allows for requiring disputes be put in writing and signed, providing the investigation is not delayed if a written form is not received. The bank's process includes beginning the investigation upon notification (oral or written) and follows up with getting a specific form signed (card processor developed).
Has anyone else heard of regulators citing for 'required use of a specific form'? If the card processor requires disputes be submitted on their form, how can the bank complete the investigation process without 'requiring' the use of a specific form?
Appreciate any thoughts or comments.