We have a customer who is disputing EFT transactions that are over five years old. How far back can a customer make Reg E claims on EFT transactions? I can't seem to find the answer in the regulation or my research.

Great question, cwalters77 and welcome to the BOL forums/threads!

The answer to this is a bit complex, but the short version is that there is no limit on how far back a customer can dispute a transaction. The late notification will, however, cancel your requirement in 1005.11 to provide provisional credit.

In your case, you won't have to give provisional credit as 1005.11 says provisional credit must be given if the consumer sends notice to "the institution no later than 60 days after the institution sends the periodic statement or provides the passbook documentation, required by § 1005.9, on which the alleged error is first reflected."

The consumer's liability under 1005.6 still applies, and as you probably know, this is going to depend on when the transaction occurred vs when they learned of the loss or theft of their device - the same as you have for any other dispute.

The bottom line is that the customer can still dispute old transactions and you must investigate them. The difference with older transactions is that you aren't required to comply with 1005.11.