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#2088767 - 07/19/16 04:01 PM Reg E Liability
ComplianceGuru89, CRCM Offline
Member
Joined: Sep 2015
Posts: 85
We have a customer disputing many gaming transactions with Google. He had the same type of transactions on a card he closed in July that he did NOT dispute. He has only had his current card for two weeks. Since all the transactions are small, we cannot do a chargeback. Typically we just take the loss on these but want to know if there is any other option? Other than closing out the card and not issuing a new device

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#2088885 - 07/19/16 10:29 PM Re: Reg E Liability ComplianceGuru89, CRCM
Natasha T Offline
Junior Member
Joined: Nov 2012
Posts: 33
California
You can request documentation from Google as to whose account the games were purchased for. If name matches your client- you have a reason to deny the claim. You can also have a conversation with the client asking about approved transactions on previous card and whether those were authorized.

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#2093183 - 08/15/16 02:37 PM Re: Reg E Liability ComplianceGuru89, CRCM
Breeco Offline
Member
Breeco
Joined: Aug 2014
Posts: 95
Nebraska
We had an ex-husband steal his wife's card out of her purse and make a purchase. She disputed it, but can the merchant represent after we made the provisional credit permanent based on fraud? Merchant's response is name and address matched card; however, they did not provide a shipping address to validate it went to her address.

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#2093186 - 08/15/16 02:42 PM Re: Reg E Liability ComplianceGuru89, CRCM
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,715
Illinois
You ability to recover funds from the merchant using the chargeback process is not related to your obligation to reimburse a cardholder under Reg E.

VISA/MasterCard chargeback rules give a merchant 45 days from the date of your chargeback to represent. If you close your investigation prior to receiving the merchant's response, Reg E does not permit you to reopen it. VISA/MC allow a merchant to represent based on "Compelling Evidence" such as a billing address match. If the purchase is an online purchase and your cardholder still asserts that she did not receive the merchandise, you may request her assistance in writing an updated dispute letter refuting the merchant's response. This can be used to file an arbitration chargeback (M/C) or pre-arbitration (V) in an attempt to continue the V/MC dispute process and recover the funds from the merchant.

Note that if your Reg E investigation determined that an EFT error did occur, you may not use a lack of customer cooperation in the chargeback process as a basis to deny the claim.
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#2093234 - 08/15/16 04:19 PM Re: Reg E Liability ComplianceGuru89, CRCM
Breeco Offline
Member
Breeco
Joined: Aug 2014
Posts: 95
Nebraska
Brian, thank you for the clarification. It's very hard to get the back office to understand that Reg E is for the consumer and Mastercard chargeback rights are for the Bank.

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