Good Afternoon!
I am hoping to garner some guidance on the following situation. Customer submitted a Reg E dispute at the beginning of the month on one transaction from the current statement. Because the amount of dispute was below the Bank's threshold for investigating, the customer was provided final credit for the transaction and the case closed.
The following week, the same customer submitted a separate dispute for the same recurring monthly transaction going back 13 months. This is a dispute beyond the timeframe, which we would only provide credit for the transactions occurring within 60 days of the initial transaction showing on a statement. However, the customer has already been given permanent credit for most recent transaction per the first dispute.
This type of "split" dispute seems to be happening with more regularity.
In cases where provisional credit was provided for the first dispute and the investigation not yet completed when the second dispute is received, our analysts have been notifying the customer that the two separate reports are all really part of the same dispute and will be investigated as such. Final credit provided to the customer in these cases follow the 60-day rule for refunding transactions.
In the case above though, since final credit was provided and case closed, can we still say/justify that it is part of the same investigation?
Any thoughts, resources, regulatory citations, or suggestions based on how your institution handles situations like this would be greatly appreciated.