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#710949 - 04/03/07 10:16 PM Reg Z - Credit Card Disputes
C_Groat Offline
Member
Joined: Mar 2006
Posts: 70
Salt Lake City, UT
Reg Z requires acknowledgment or resolution within 30 days of receiving the error, does the monthly billing statement reflecting the credit for the unauthorized activity provide sufficient acknowledgement or does a seperate letter need to be sent, something similar to a Provisional Credit Letter from Reg E?

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eBanking / Technology
#713214 - 04/07/07 02:19 PM Re: Reg Z - Credit Card Disputes C_Groat
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,602
Galveston, TX
From the OSC:

13(e) Procedures if billing error occurred as asserted.

2. Form of correction notice. The written correction notice may take a variety of forms. It may be sent separately, or it may be included on or with a periodic statement that is mailed within the time for resolution. If the periodic statement is used, the amount of the billing error must be specifically identified.

If a separate billing error correction notice is provided, the accompanying or subsequent periodic statement reflecting the corrected amount may simply identify it as credit.

13(f) Procedures if different billing error or no billing error
occurred.

2. Form of creditor's explanation. The written explanation (which also may notify the consumer of corrections to the account) may take a variety of forms. It may be sent separately, or it may be included on or with a periodic statement that is mailed within the time for resolution. If the creditor uses the periodic statement for the explanation and correction(s), the corrections must be specifically identified. If a separate explanation, including the correction notice, is provided, the enclosed or subsequent periodic statement reflecting the corrected amount may simply identify it as a credit. The explanation may be combined with the creditor's notice to the consumer of amounts still owing, which is required under 226.13(g)(1), provided it is sent within the time limit for resolution. (See Commentary to 226.13(e).)
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#714297 - 04/10/07 08:45 PM Re: Reg Z - Credit Card Disputes rlcarey
Compliancer Offline
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Compliancer
Joined: Jan 2006
Posts: 334
San Francisco, CA
When including it on the statement, you can use the issuance of the credit as notice. The line item description must identify the credit as related to a dispute resolution claim. You may wish to create a new system code for the issuance of such credits. Good verbiage to use as an identifier is "dispute provisional credit" and "dispute resolution credit", depending on which type of credit you are issuing.
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