Hello BOL. I've searched the site without much luck, so I apologize if this has been asked.

We have received a card dispute for unauthorized transactions on an HSA debit card. Our operations team is wanting to deny the claim because HSA accounts are not covered by Reg E and are of the same understanding these are also exempt from Mastercard's Zero Liability protections, based largely on the following from MC's website, "For additional protections with respect to unauthorized transactions, please contact your bank or credit union." The rationale is that because MC directs the customer back to the FI, it puts the onus on the FI to determine liability, and since these are exempt from Reg E, the liability belongs to the customer.

I have always understood MC branded cards (including HSA) are covered by their zero liability protections, but I can't find a reference to it. Can someone confirm these are covered? (preferably with a MC citation). Or if I'm wrong, the same request - can someone please provide confirmation, again - preferably with a MC citation.

Thanks!

Key word there is "additional" protections. Regulation E 1005.11 provides protections for much more than just unauthorized charges which a Mastercard cardholder is invited to contact you to find out more. There is no possible grammatical hurdle that would allow you to conclude that "additional protections" to Zero Liability equates to "fewer protections."

Mastercard covers debit cards issued in connection with HSA accounts. Review your BIN license as I am quite sure there is a clause in there that obligates you to provide Zero Liability protections. If you're still not sure, the next calls are to your legal counsel and your Mastercard representative.

Thank you! Always greatly appreciate your guidance, Brian.