If our volume exceeds the Safe Harbor limit and we start complying with the rule, can we re-qualify for the Safe Harbor exemption if our volume is reduced to under 500 transfers a year?
What does “UBPR” stand for?
If there is more than one grantor/trustee, as in a joint trust, upon the death of the grantor whose SSN was used, can the SSN of the surviving grantor then be used?
A Regulation E unauthorized entry claim was received on 4/14/2021 for 4 bankcard purchases of $499.99. The transactions occurred on 12/18/2020. The first statement for which those transactions appears was also 12/18/2020. The bank determined no error occurred due to untimely notice based on § 1005.11(b)(1)(i). (The 60th day would've been 2/16/2021.) The client states the error was first noticed 4/14/2021 (the card was closed 4/14/2021.) According to the client's error claim, the card was never lost nor stolen. A testing report states the claim should've been deemed an error based on §1005.6(b)(1) because the client gave notice within 2 days of noticing the error. Does section §1005.6(b)(1) only apply when an access device is lost or stolen and would the client would still need to provide notice within 60 days from the statement the error first appeared for the liability tiers to apply? Please clarify the proper outcome for this case and provide more clarity on if 1005.6(b)(1) and how it applies after 60 days from the statement on which it first appeared and if it only applies for lost/stolen access devices.
Where are the CFPB FAQ's Andy has referenced as “required reading” when dealing with Reg E claims?