When we report that a claim has been denied because "no error was found" in writing - is it enough to simply state "No error was found" in the written explanation we deliver to the client, or should it also explain how we came to that determination? Either way, we will also note the client's right to request the documents relied on, but I am not sure how much detail satisfactorily explains our findings.

It is not like an adverse action notice. No requirement to provide a reason.

I have audited Reg E programs where a bank has 40-50 denial letter templates because they wanted a specific reason for every possible denial senario. If their grand efforts to overcomply, they ended up having letters with invalid denial reasons that violated Reg E (e.g. "Failure to provide additional documentation", "PIN used to complete transaction, etc.) or they would grab the wrong template and send a reason that had nothing to do with that particular investigation.

Keep it siimple and stick to the requirements of 1005.11(d).
1. We determined that no error occurred.
2. You have the right to request documents on which we relied to make our decision.
3a. We revoked your provisional credit and will honor checks and preauthorized debits for five business days.
3b. We will debit your provisional credit in five business days.

Hi, me again. So after asking this I went on my merry way. Today, I was reviewing page 10 of the CFPB's Supervisory Highlights (09_2020) for fun. Section 2.3.3 states that 12 U.S.C. §§ 1693f(a) and 1693f(d) and 12 C.F.R. § 1005.11(d)(1) "require a financial institution investigating an alleged EFT error to communicate to consumers, among other elements, (1) the investigation determination; and (2) an explanation of the determination when it determines that no error or a different error occurred within its report of results."
And that a notice must "give purpose to both obligations, the meaning of an “explanation” is not synonymous with that of a “determination.” Financial institutions must go beyond just providing the findings to actually explain or give the reasons for or cause of those findings."

And that "when the financial institutions determine no error or different error occurred.. ensure that the letter provides: (a) the determination; (b) an explanation of the financial institution’s findings; and, (c) a statement noting the consumer’s right to request the documents relied on in making the determination..."

Reg E doesn't break the notice into those three components, but it sounds like the CFPB has made examination findings on it if all three aren't there...thoughts?

https://files.consumerfinance.gov/f/documents/cfpb_supervisory-highlights_issue-22_2020-09.pdf

it appears the CFPB is doing many things without regard to historical processes or long-standing "spirit of the law" guidance. My opinion, if they can make a bank change something to make it in favor of a customer, they will, regulatory guidance be damned. they are changing regulations by exam finding.