We have a customer that received a text from "Amazon" saying that she was going to receive some type of refund (for an order that she did not do) and she clicked the link, gave whoever it was the authority to download software on to her phone and let them log into her Amazon account. They ended up running two different debits through her CASH APP for $455 each. She says she watched them do all of this and gave them permission to have access, even giving them a copy of her D.L. She says that she was clicking ok and allowing these transactions throughout the process. She is now disputing these charges. Are we obligated to reimburse this money?

We have been honoring these disputes as unauthorized transfers per the CFPB FAQs. If she had keyed the Cash App transactions, we would have treated it differently.

An unauthorized EFT is an EFT from a consumer’s account initiated by a person other than the consumer without actual authority to initiate the transfer and from which the consumer receives no benefit. 12 CFR 1005.2(m). Unauthorized EFTs include transfers initiated by a person who obtained a consumer’s access device through fraud or robbery and consumer transfers at an ATM that were induced by force. Comments 2(m)-3 and 4.

Agree. This is an example of an "access device obtained through robbery or fraud" as noted in the commentary to 1005.2(m). The cash app debits meet the definition of an unauthorized EFT.

Update to this question. I spoke with the CSR that is working this case, and she said that the customer did do the transactions herself. They did not have access to her phone they told her to download some App. for bitcoin on her phone, and then she moved the money from her CashApp to this downloaded App. with their instruction. Sorry for the mistake.

Now it's a deniable claim that fits under the "authorized fraud" that some in DC want the CFPB to protect consumers from. But we aren't there yet as she conducted the transfers.

Personally she thought she was going to pay a little to get a bigger refund she knew she wasn't owed and I have no sympathy for the person.

Thanks for your responses!