Do error claims involving Person to Person transactions (Such as Venmo, Cash App, Zelle, etc.) qualify for the 90-day extension of time period for investigation for point-of-sale debit card transactions? (12 CFR 1005.11(c)(3)(ii)(B))

In my opinion, they do not because they are not debit card transactions

I'm getting pushback from management. I don't quite understand the chargeback/recovery process but apparently our processor, who attempts to recover the disputed P2P funds, does not respond until 45 days has past. The timing would not provide us enough time to conclude the investigation, therefore management believes the processor is considering P2P transactions the same as point-of-sale debit card transactions.

It depends. Those transactions can either be processed on the Nacha network via ACH or on the debit card network if the customer attached their debit card to the mobile wallet.

If it is processed via ACH, its 45 days. If it is processed via the debit card network, then it is point of sale and 90 days. Look at the commentary to 1005.11(c) which describes the extensive definition of what qualifies as point of sale.

1. POS debit card transactions. The extended deadlines for investigating errors resulting from POS debit card transactions apply to all debit card transactions, including those for cash only, at merchants' POS terminals, and also including mail and telephone orders. The deadlines do not apply to transactions at an ATM, however, even though the ATM may be in a merchant location.