There are two sections of Regulation E at work here. Brenda has correctly cited §205.11 for error resolution. The customer has to notify you within 60 days of the statement on which the alleged error first appears in order for the customer to be covered by the protections of §205.11. So, if the customer comes in five months after the string of errors begins, you don't have to apply §205.11 to whatever you do to work with the customer.
Then there is §205.6(b)(3), which deals with limits on customer liability. The customer is entitled to relief for any unauthorized transaction (UT) that occurs from the first such UT until 60 days after the statement showing that first UT is made available (subject to the $50/$500 rule if an accepted access devise was involved). After that 60th day, the customer is liable for any further UTs until he notifies you.
That part of the liability rules sort of parallels what happens if there were unauthorized checks paid on the account.
The parallel ends there, though. Where the UCC has a one-year limit on maker's signature, for example, there is no equivalent provision in Reg. E. If the customer comes back, in theory, 5 years later, he can still enter a claim for those UTs occurring before the end of the 60 days following the first statement showing the first such UT.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8