I have a question about how we have to handle re-opened disputes. We have some customers, who after being found out that their dispute was denied, continued to re-open the dispute hoping for a different outcome. Do we have to re-open a dispute if no new information is provided? What would meet the definition of new information? If the story changes slightly, would that trigger a brand new investigation? Or can we require something more substantial?

(e) Reassertion of error. A financial institution that has fully complied with the error resolution requirements has no further responsibilities under this section should the consumer later reassert the same error, except in the case of an error asserted by the consumer following receipt of information provided under paragraph (a)(1)(vii) of this section.

Randy - I have seen that citation, but it's unclear to me if that means new information needs to be provided or if they can simply state I want the dispute re-opened and another investigation to take place.

Not unless they provide you with actual new information. New information does not include changing their story. They only get one shot at making something up.

Thank you Randy.

The only time I opened an investigation was during an exam. The customer provided a questionable story about opening the new account, doing home and putting everything in a safe, not using it, and finding the safe opened and their money transferred out. They never responded to phone calls as we tried to get fact and eventually we sent them certified, return receipt requests for info. They never responded and never asked about getting their money. We closed the claim as denied because based on the information we had, nothing lead us to believe they were done by anyone else.

The problem is the unopened returned certified mail had the address numbers transposed. So whoever lived where we sent it didn't claim it. We started over with the right address. The examiner caught the transposition, we didn't. We saw this as the possibility of getting new info. But the customer never claimed the correctly sent letter and had still never followed up asking where their money was. It was a scam.

Andy we see a tremendous amount of fraud, especially with our prepaid cards. ATM non-disputes is the leader by far, but we are also seeing other types of fraud develop. We are trying to find a balance where consumers can get their funds returned, without turning over the keys to the kingdom to the illicit actors.