Question on the timing of a claim. Customer came in the bank on 9/6/2022 because he received a call from the fraud department. The charge he was called about was stopped and never posted to his account. He closed his card at this time and we assisted him in reviewing his account. At this time he stated there were no charges that were unauthorized on his account. Then on 9/17/2022, he filed a claim on a charge from 8/31/2022 for $39.95 from the same merchant the card was originally flagged for. We added it to the same claim from 9/6/2022 (even though there was never an original charge posted to his account). Credit was provided to the customer on 9/26/2022. By adding it to the original claim, we are now over the 10 days for provisional credit, as the original claim was opened on 9/6/2022.

Did this need to be added to the same claim, or should we have closed the original claim, and opened a new claim?

I am not sure why you would ever add a new claim to an old claim that had already been resolved.

Me neither. I'm reviewing the claims for last month and before I contacted the Reg E department about this, I was just making sure I was thinking correctly in that this should have been a separate claim.

Your research should be able to determine when a consumer makes a repeat claim on the same transaction(s).

We use a third party for Reg E disputes and have that phone number on our Reg E disclosures. If a customer calls the bank with a dispute and we give them that phone number to call for disputes, does the clock start when the customer calls the third party, or does it start when the customer called the bank?

CFPD states "Notice at particular phone number or address. A financial institution may require the consumer to give notice only at the telephone number or address disclosed by the institution, provided the institution maintains reasonable procedures to refer the consumer to the specified telephone number or address if the consumer attempts to give notice to the institution in a different manner."

Since the commentary defines that "notice" can be required to be given at a particular phone number or address, the "notice of error" that starts the clock is when the customer call the phone number in your disclosures.