It is not just the physical card that is your access device; it is also the card number.
Reg E 1005.2(a)(1)(a)(1) “Access device” means a card, code, or other means of access to a consumer's account, or any combination thereof, that may be used by the consumer to initiate electronic fund transfers.
If the cardholder had knowledge in November that their card number had been stolen, and you determine that Zero Liability does not apply because the cardholder was negligent (VISA) or did not report the loss promptly (MasterCard) you may be able to impose greater liability depending on when the transactions posted in relation to the cardholder learning of the loss/theft of the card number.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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