We received two disputes for two different cards under the same account holder and account. Can we treat this as one claim? or do we need to treat each one separately? Customer is disputing transactions from January and want to make sure whether we can treat it as one claim and use the 60 day rule.

Thanks,

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.

The cards were not active at the same time - different card numbers. when the 1st card was canceled, a 2nd card was issued. Customer is just submitting the claims for both cards. It was not lost or stolen - cards were in their possession. Some transactions were run using the chip.

Thank you

Just for background, why did the customer cancel the first card (I'm assuming they had not spotted the unauthorized transactions at that point)?

The first card was canceled because it was compromised. These transactions are chip based. There are some transactions from the same merchant that are not being disputed. it just doesn't seem like these transactions are unauthorized, especially since they were used with the chip.

Unless you can get photo evidence it was your customer, you'll probably end up eating these transactions. If the customer didn't do them and still has possession of the card, it is a family member or friend who has access to wherever they keep the card - I doubt some stranger is periodically stealing and returning the card. I wouldn't re-issue.