Reg E Dispute- older than 60 days-NOT Unauthorized

Posted By: M&M

Reg E Dispute- older than 60 days-NOT Unauthorized - 10/26/20 06:19 PM

I'm second guessing myself and spending way too much time on rehashing this.

If I have a dispute that is NOT unauthorized, but is disputed outside of the 60 day timeframe, can we just deny the dispute and be done? Or do we have to accept and investigate it but just not follow the timeframe rules or provide PC?
Posted By: rlcarey

Re: Reg E Dispute- older than 60 days-NOT Unauthorized - 10/26/20 06:30 PM

What is a "dispute that is NOT unauthorized"?
Posted By: BrianC

Re: Reg E Dispute- older than 60 days-NOT Unauthorized - 10/26/20 06:33 PM

Perhaps a dispute that falls under the category of an "incorrect EFT."

For example, I authorized $100.00, but I was charged $1,000.00. Since 1005.11 does not apply when notice is late, and the transaction is not considered unauthorized so 1005.6 liabilities are not triggered, then the institution would not have any obligation to investigate the claim and could deny it for late notice.
Posted By: M&M

Re: Reg E Dispute- older than 60 days-NOT Unauthorized - 10/26/20 06:34 PM

Any of the other definitions of an "error" under Reg E other than unauthorized.
Posted By: M&M

Re: Reg E Dispute- older than 60 days-NOT Unauthorized - 10/26/20 07:05 PM

Thanks BrianC. That's exactly what I was trying to confirm. I've always provided guidance to that effect, but I saw a Reg E dispute workflow that incorrectly referenced this requirement, and it made me second guess myself. Appreciate your help.