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#2267466 - 03/10/22 05:23 PM Reg Z - No Error Occurred Explanation
JR00K Offline
New Poster
Joined: Feb 2021
Posts: 7
Hello All,

In review of 1026.13(f)(1), there has been some questions regarding the extent of explanation required to remain compliant with the CFPB.

(f)If, after conducting a reasonable investigation, a creditor determines that no billing error occurred or that a different billing error occurred from that asserted, the creditor shall within the time limits in paragraph (c)(2) of this section:

(1) Mail or deliver to the consumer an explanation that sets forth the reasons for the creditor's belief that the billing error alleged by the consumer is incorrect in whole or in part;

Specific to claims of fraud, what information have you all seen as being required to provide? The concern I have is providing too much information, allowing the cardholder to file a better false fraud claim in the future. I want to remain as vague as I can, but also ensure we're staying in the good graces of auditors.

Thank you!

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#2267482 - 03/10/22 08:12 PM Re: Reg Z - No Error Occurred Explanation JR00K
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,828
Pulling people out of the ditc...
You should provide sufficient information specific to the reason you are denying the claim, in plain english, that the customer can understand why the decision was made and the claim denied. If you are intentionally being vague, that is where you run risk from the regulators.

and once you have made your determination, and you feel this customer is a fraudster, why would you allow the account to remain open so he can "file a better fraud claim in the future?"
Providing alternative truths since the invention of time

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