Posted By: CU3840
Reg Z Billing Dispute on Credit Card - No Error - 07/14/21 05:43 PM
If a customers credit card billing dispute is investigated and the bank deems the results as "no billing error occurred" under 1026.13(f), what is the timeframe requirement in which the creditor must 'rebill' the disputed amount back to their credit card? It appears Reg Z is silent on this, unless I'm blind!
Does the disputed amount need to be REBILLED by the Reg Z date (within 2 complete billing cycles) or (in no event later than 90 days after after receiving a billing error notice)? What's the correct answer?
1026.13(c)(2) states: The creditor shall comply with the appropriate resolution procedures of paragraphs (e) and (f) of this section, as applicable, within 2 complete billing cycles (but in no event later than 90 days) after receiving a billing error notice.
1026.13(e) - If a creditor determines that a billing error occurred (resolve in CH favor) as asserted, it shall within the time limits in paragraph (c)(2) of this section:
(1) Correct the billing error and credit the consumer's acct w/any disputed amount and related finance or other charges, as applicable; and
(2) Mail or deliver a correction notice to the consumer.
1026.13(f) Procedures if different billing error or no billing error occurred. If, after conducting a reasonable investigation, a creditor determines that no billing error occurred (charge is valid) or that a different billing error occurred from that asserted, the creditor shall within the time limits in paragraph (c)(2) of this section:
(1) Mail or deliver to the consumer an explanation that sets forth the reasons for the creditor's belief that the billing error alleged by the consumer is incorrect in whole or in part;
(2) Furnish copies of documentary evidence of the consumer's indebtedness, if the consumer so requests; and
(3) If a different billing error occurred, correct the billing error and credit the consumer's account with any disputed amount and related finance or other charges, as applicable.
Does the disputed amount need to be REBILLED by the Reg Z date (within 2 complete billing cycles) or (in no event later than 90 days after after receiving a billing error notice)? What's the correct answer?
1026.13(c)(2) states: The creditor shall comply with the appropriate resolution procedures of paragraphs (e) and (f) of this section, as applicable, within 2 complete billing cycles (but in no event later than 90 days) after receiving a billing error notice.
1026.13(e) - If a creditor determines that a billing error occurred (resolve in CH favor) as asserted, it shall within the time limits in paragraph (c)(2) of this section:
(1) Correct the billing error and credit the consumer's acct w/any disputed amount and related finance or other charges, as applicable; and
(2) Mail or deliver a correction notice to the consumer.
1026.13(f) Procedures if different billing error or no billing error occurred. If, after conducting a reasonable investigation, a creditor determines that no billing error occurred (charge is valid) or that a different billing error occurred from that asserted, the creditor shall within the time limits in paragraph (c)(2) of this section:
(1) Mail or deliver to the consumer an explanation that sets forth the reasons for the creditor's belief that the billing error alleged by the consumer is incorrect in whole or in part;
(2) Furnish copies of documentary evidence of the consumer's indebtedness, if the consumer so requests; and
(3) If a different billing error occurred, correct the billing error and credit the consumer's account with any disputed amount and related finance or other charges, as applicable.