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#2280584 - 02/02/23 09:44 PM Reg E Disputes & Record Retention
BSL87 Offline
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Joined: Dec 2022
Posts: 4
If a financial institution purges account statement information after 7 years and dispute data after 2 years (as required by Reg E). What is the FI's responsibility if a customer files a Reg E debit card dispute beyond 7 years?

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#2280588 - 02/02/23 10:53 PM Re: Reg E Disputes & Record Retention BSL87
Valley girl Offline
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Joined: Aug 2014
Posts: 365
TX
Thank heavens I never will have to find out. As a CU, we are required to keep statements permanently, 12 CFR 749. I imagine you would have to give them whatever they said had happened. I would be really careful about how I phrased my request for a copy of their records.

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#2280624 - 02/03/23 06:28 PM Re: Reg E Disputes & Record Retention BSL87
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 81,309
Galveston, TX
Originally Posted by BSL87
If a financial institution purges account statement information after 7 years and dispute data after 2 years (as required by Reg E). What is the FI's responsibility if a customer files a Reg E debit card dispute beyond 7 years?

None.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2280725 - 02/07/23 02:44 PM Re: Reg E Disputes & Record Retention rlcarey
BSL87 Offline
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Joined: Dec 2022
Posts: 4
Thanks. If there's no statute of limitations for filing a Reg E claim and financial institutions cannot deny claims for solely being out of timeframe, how would the bureau expect the FI's to respond to such claims when no records are available due to retention standards. Wouldn't the FI still be expected to perform a reasonable investigation? If so, how do we perform that with no records?

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#2280736 - 02/07/23 03:52 PM Re: Reg E Disputes & Record Retention BSL87
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 81,309
Galveston, TX
You cannot - so there is nothing to do. Plus, is this just a hypothetical exercise and why are we going through it? If you want a solid answer- present your question to the CFPB.

https://reginquiries.consumerfinance.gov/
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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