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#1810884 - 05/03/13 06:09 PM Reg E & Revocation
NegGhostrider Offline
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NegGhostrider
Joined: Mar 2011
Posts: 93
So let me give you a scenario:

We gave provisional credit to a customer for their disputed transaction. During our investigation period the merchant had given the customer their money back by crediting their account. This means the customer now has double credit for the transaction in question. Now in seeing this we take back our provisional credit which causes the customer to now be insufficient.

Does this still fall under the Reg E where they can't be charged due to "revocation" even though the bank is just taking back the additional credit that the customer received?

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Operations Compliance
#1810910 - 05/03/13 06:35 PM Re: Reg E & Revocation NegGhostrider
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Was the credit still in the provisional stage or was it final?
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#1810945 - 05/03/13 07:06 PM Re: Reg E & Revocation NegGhostrider
NegGhostrider Offline
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NegGhostrider
Joined: Mar 2011
Posts: 93
The bank was still in the investigative stage when the merchant credit was given. So we took back the provisional credit that was given.

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#1810963 - 05/03/13 07:26 PM Re: Reg E & Revocation NegGhostrider
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Right decision, wrong tool. By revoking the provisional credit, you triggered the overdraft coverage rule. But if you finalized the investigation by making the provisional credit final, BUT announcing you're taking back the duplicate payment received from the merchant, I think you avoid the overdraft coverage trap.

Is Brian in the house?
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#1810970 - 05/03/13 07:33 PM Re: Reg E & Revocation NegGhostrider
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
My ears were definitely ringing...I concur with John's opinion. When faced with this situation, I send the customer a "final credit" letter in which I state that I have determined that an error did occur and I am finalizing provisional credit. I also state that the customer received a duplicate credit on MM/DD/YY and that I am reversing the duplicate credit.
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#1811012 - 05/03/13 08:06 PM Re: Reg E & Revocation NegGhostrider
NegGhostrider Offline
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NegGhostrider
Joined: Mar 2011
Posts: 93
Thank you all for the great information.

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