If we disclose to our customers in the initial disclosure that all Reg E disputes must in writing and the customer orally submits a dispute, but doesn't follow up in writing, can we deny the claim?
If a customer lets someone use their debit card and they've given them the PIN, when they fill out a Reg E claim stating another person was unauthorized to use their card, do we have to honor the claim?
What is the best practice for handling debit cards returned in the mail to the bank?
Our bank charges a $25 EOM overdraft service charge fee for any account that have been overdrawn within the statement cycle. My question is, are we allowed to charge a $25 EOM fee to a Reg E opt-out account that was overdrawn by a one-time or point of sale item?
The bank did not charge for the item but still does charge at the EOM maintenance fee for being overdrawn.
We have a Visa POS Dispute from a customer as fraudulent card in possession, however it was through PayPal and verified by Visa. She stated she did not have a PayPal account. The dispute came back as no recourse since Verified by Visa was used. Is this sufficient to reverse provisional credit?
When the bank processes a merchant dispute on behalf of the customer and it does not fall under Reg E, are we under the same time frame as Reg E as far as 10 day provisional and finalizing the dispute within 45 days?
What if we sent a letter to them after the 45 days and then the merchant rejects the claim with valid information, can we go back and debit the customer?
We currently provide the Reg. E disclosures on the back of our card carriers. All disclosures are provided at account opening but the disclosures on the card carriers were added as an extra step. Is this a common practice for other banks?
One of our customers filed a dispute for "unauthorized transactions." Upon our initial investigation, we found that the customer had a pattern of activity with this merchant, and so denied the dispute based on the facts we discovered. The customer is now wishing to add additional charges to the dispute (but not all charges).
Under 12 CFR 1005.11 (e), it states "A financial institution that has fully complied with the error resolution requirements has no further responsibilities under this section should the consumer later reassert the same error, except in the case of an error asserted by the consumer following receipt of information provided under paragraph (a)(1)(vii) of this section."
We believe we fully complied with the requirements of Regulation E during the initial investigation. Are we required to reopen the dispute, provide provisional credit again, and perform a second investigation?
What forms per regulations/laws, besides disclosures, are required for a new customer opening deposit accounts, including IRAs?
If a bank completes its investigation and sends the consumer a final letter stating the claim has been closed and the provisional credit is now the final credit, but later determines that the consumer is actually liable for the transaction, can the bank change it's mind and send a provisional credit reversal letter and debit the consumer's account, as long as it's within the time limits set by Reg E?
For an example, the final letter is sent on day 35 closing the claim. Five days later, additional information is discovered that shows the consumer is responsible. So on day 41, from the date of notice, the bank reopens the claim and sends a new letter to the consumer to reverse the provisional credit.