Reg E 1005.11(b) only requires that the member provide their name, enough information to identify their account number, and why they believe an error exists including dates and dollar amounts of transactions. You cannot deny a claim because a member does not or cannot provide additional documentation that may be needed to file a chargeback.
The Visa/Mastercard chargeback process is one method for investigation a Reg E claim, but the lack of chargeback rights does not give you reason to deny a claim. You must consider other options such as contacting the merchant directly, reviewing information on the merchant's website (such as contract info) or just paying the claim. The CFPB makes this very clear in their recent Reg E FAQs6. Can a financial institution require a consumer to file a police report or other documentation as a condition of initiating an error resolution investigation?
No. A financial institution must begin its investigation promptly upon receipt of an oral or written notice of error and may not delay initiating or completing an investigation pending receipt of information from the consumer. See Comments 11(b)(1)-2 and 11(c)-2. In the past, Bureau examiners found that one or more financial institutions failed to initiate and complete reasonable error resolution investigations pending the receipt of additional information required by the institution. These examples can be found in the Bureau’s Summer 2020 edition of Supervisory Highlights and Fall 2014 edition of Supervisory Highlights . The Bureau cited similar violations in 2019-BCFP-0001.
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