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#2271707 - 06/15/22 05:50 PM Reg E Claim and OD Fees - 60 Days
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 899
If a customer reports unauthorized transactions that go back more than 60 days and we determine an error did occur, we would refund any unauthorized transactions plus interest plus any fees incurred during the 60 day period after the first statement the first error occurred on. If there are overdraft fees that occurred after the 60 day period, do we have to refund them also? Or since they are outside of the 60 day time frame can we leave those alone?

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#2272276 - 06/29/22 05:36 PM Re: Reg E Claim and OD Fees - 60 Days Bankwoman1
John Burnett Online
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John Burnett
Joined: Oct 2000
Posts: 39,686
Cape Cod
The intent of the rule is that the customer be made whole with respect to unauthorized EFTs that the bank must reimburse the customer for. So any overdraft fee that would not have been charged if the unauthorized EFT had not happened should be reversed, regardless of how separated in time the unauthorized EFT was from the OD fee.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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