The answer depends on whether the errors being reported are related or not. See 1005.6 (b)
(b) Limitations on amount of liability. A consumer's liability for an unauthorized electronic fund transfer or a series of related unauthorized transfers shall be determined as follows:
Questions you need to answer:
1. If the errors in January on card #1 had been reported, would you have been able to stop subsequent errors from occurring on card 2?
2. Different card numbers issued to the same person or the same card number issued in two different cards?
3. Were the errors due to a lost/stolen card?
4. If yes, were both cards stolen at the same time or at different times?
5. If no, were the cards compromised as a result of the same incident, seperate incidents, unknown?
The purpose of the above questions is to help you conclude if the error claims you received are a "series of transactions" or seperate incidents. The answer to your question could go either way depending on the circumstances of the claims.
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