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Close Investigation Before 45/90 Days Reg E

Is it considered a law violation to close the investigation prior to the extended periods of 45 and 90 days, even when you provisionally credited the client and complied with all the Reg E requirements?

Answer by Brian Crow: The 45/90 peiod is the MAXIMUM that your investigation may take. If you conclude your investigation sooner, Sections 1005.11(c)(2)(iii-iv) require that you correct the error and notify the customer once you have reached a conclusion.

(iii) Corrects the error, if any, within one business day after determining that an error occurred; and

(iv) Reports the results to the consumer within three business days after completing its investigation (including, if applicable, notice that a provisional credit has been made final).

It is actually a violation to reach a conclusion and then sit on the results until the 45/90 period elapses.


Answer by John Burnett: Just don't forget that you probably ought NOT reach the conclusion if there's a potential for a Visa or MasterCard disputed transaction to be resubmitted by the merchant, because you won't be able to recover the funds from your cardholder if you've provided notice that your investigation is finalized.

First published on 2/04/13.

First published on 02/04/2013

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