Reg E Confusion

Our customer notified us 11/21 of four unauthorized debit card transactions but also called the merchant and was promised a full credit in 10 business days. Two of the transactions were credited back. Now on 12/9 the customer notifies us that he again called the merchant (also on 12/9) about the other two transactions and was told that they would not be credited back because they were gift card purchases. If we submit a chargeback today does our time frame start today or on 11/21? Also, is the reason the original unauthorized transaction or the missing credit?

Well, if none of these were credited back in the first 10 business days, you should have issued provisional credit. Your rights to chargeback have nothing to do with your liability to the consumer to correct.

The Reg E clock started on 11/21. Reg E states you may request, but cannot require, additional effort on the part of your customer, right?...As in, merchant contact. So the fact that your customer did contact the merchant, didn't [really] change much.

In similar situations, we have acknowledged the merchant's promise to refund, but we started the timer on the same day we were notified. We monitor the account as long as we can (10 business days). If the refund has been satisfied in full, we close the dispute and notify the customer. If no refund has been issued, or issued for a smaller amount, we issue provisional credit and begin the merchant dispute process.

So we clearly dropped the ball on the 10 days for provisional credit, but going forward on this case, what would the reason for the dispute be if we submit it at this point? Unauthorized Transaction or that the credit is missing?

Unauthorized debit transaction

Unauthorized.

Generally, "credit not processed" occurs when a merchant agrees to - but doesn't - refund an authorized transaction.

Thank you both!