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In Response To:
Thread Starter: rainman
Title: Re: Card Dispute Question - Unauthorized/Authorized

I would not want to have a record that 15 were investigated and the rest were ignored. Your bank may choose to outsource its investigation function but it can't outsource the obligation for compliance. The core processor needs a better answer than "we can only submit 15 to MC." That is an issue that goes beyond this particular matter.

But Randy's point is on target. You already have evidence of who did the transactions. Check your records and review any other available information about the situation. Is there any evidence that some other party (not the co-worker) did the transactions? If not then you have evidence of who did them, and you have no contrary evidence, and based on your cardholder's statements the transactions were not "unauthorized" within the meaning of Reg. E.

But you can't say that you didn't conduct an investigation but still concluded the transactions were unauthorized. That is simply handing the regulator a baseball bat and saying "please hit me."