I am running into a problem with the investigative process on EFT Disputes.

We contract with a vendor that provides our debit cards and processes transactions. When there is an error we have to submit it to that vendor for investigation. The vendor requires a written form to be completed and signed by our customer before we can even enter the information on their system. Without that we are unable to really move forward in the investigation.

I am looking for any guidance that can be provided on how to handle a dispute when the customer notifies the bank of an error over the phone, the bank mails the dispute form required by the vendor with instructions and advises if they have any questions to come in and speak with a banker and the form is never returned. We are unable to get the investigation off the ground to help our customer resolve their complaint.

Can we deny the claim based on "Not enough information to complete the investigation"?

If you truly don't have enough information to complete the investigation, you can deny it. However, if the customer provides you with information over the phone, you have a legitimate claim that you must process. Reg E does not require the customer to complete a written form. If the customer notifies you and you can't get reimbursed from your vendor, it's a cost of doing business - unfortunately.

I agree with David - if you have the information you need to investigate a claim then you (or your vendor) must proceed. I state it that way on purpose because while you contract with your vendor, you still have the ability to conduct an investigation on your own. This may not be a prudent or even doable given how much free time you may (not) have but it is an option.

However, while you must perform an investigation, if you advise the customer you require the dispute to be in writing then you can withhold issuing credit upfront if a written response is not received within the time limit given in Reg. E (10 days).

Remember, under reg E (205.11(b))the customer doesn't really have to give you very much information to get protection. All they have to give you is 1)name and account number 2)why they believe there is an error and 3)to the extent possible, the type, date, and amount of error.

If they've given you that information, then you can't really deny it for "not enough information". They've given you all that is required.