I realize with Reg E, the majority of the burden falls on the bank to prove an EFT was unauthorized. As I understand, the customer has a responsibility to indicate why an error exists, the type, date and amount of the error. With this in mind-Is it sufficient grounds to deny a claim if the customer cannot give an accurate list of unauthorized ATM withdrawals? The customer admits to guessing at the unauthorized withdrawals because she doesn't keep a register or receipts.

If the customer says they didn't do A, B, C or D and your investigation reveals that cameras were at A and C and the customer was pictured in both, they run the real risk of being denied for the entire claim, A-D, because they were seen as the customer.

Bottom line, I would tell them this and that they cannot guess. They are filing a claim with an insured institution and attempting to recover funds apparently lost to theft. They need to be more certain than to just tell you to verify all the transactions. I would also say that short a big relationship, I'd give them a new account packet for the bank down the street and/or no more ATM/debit cards.

Not to put too fine a point on C Askew's question, but burden falls on the bank to prove that an EFT was authorized. Once the notice of alleged error is given by or on behalf of the consumer, the EFT is presumed to be unauthorized, and the bank has to determine (prove is perhaps too strong a word) that it was instead authorized.