Chance that we don’t have an agreement with a P2P

Answered by:

Question:

What if it was our debit card used with the P2P vendor with which we do not have an agreement - can we refer our customer back to the 3rd party for error resolution?

Answer:

If your bank and the P2P each have an ACH agreement and each accept the
same debit cards, the CFPB opines that you do have an agreement with them. It
doesn’t matter that you have any relationship with the P2P vendor, but you share
common financial channels and to the CFPB that is enough.
I believe it will be rare that the bank will not have an “agreement” as defined by the
CFPB, but if you truly do not, 1005.14 will apply and the vendor will have responsibilities
for the investigation.