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#2257477 - 07/30/21 07:56 PM More Reg E Questions
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
I have some additional Regulation E questions that I was hoping to get feedback on. We have seen an uptick in oral disputes and when we reach out to the cardholder (This is a prepaid card program) for additional information we often don't hear back from the customer. We do start our investigation but would like to delay the PC until we complete our review. Are we able to delay the PC on oral disputes if the cardholder does not respond to our inquiries?

If we are unable to make a determination because we don't hear back from the cardholder are we able to deny the claim?
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#2257481 - 07/30/21 09:36 PM Re: More Reg E Questions ACBbank
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,325
On the Net
1005.18 has details on error resolution for prepaids and there are a bunch of new variables to consider. (FWIW, I have not researched this. You're the first banking asking that I have seen.) Is it payroll, has the ID of the consumer been verified?

Generally speaking it does reference back to 1005.6 and 1005.11 when these rules apply and those I am familiar with. Did you require a written confirmation of the claim and provide the mailing address? When following 1005.11 if you did this you can avoid provisional credit when there is not a timely response to your request.
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AndyZ CRCM
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