John - I am curious to find out the authority for your determination that the day of claim receipt is day zero? I have been struggling with that issue recently as I try to give guidance to system programmers.
Based upon your determination of when day 1 is:
Customer makes a claim under Reg E at 8:00 a.m. Monday morning, day 1 doesn't start until Tuesday, then in essence you have a full business day extra to complete your investigation or give provisional credit? And if such is the case, when is provisional credit deemed timely given, according to the "within 10 business days" requirement of Reg E?
I don't find anything in the commentary or supplementary guidance, and have been unsuccessful in finding any caselaw on point. Any help you could give would be greatly appreciated.
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