Debit Card Fraud - Provisional Credit Time Frame

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Question:

What is the longest amount of time we can take before giving the customer final credit or declining their request with fraudulent transactions on a debit card after provisional credit has been given?

Answer:

Reg E Section 205.11(c) specifies the time frames. Assuming you've properly disclosed in your EFT error resolution disclosures, if you've given provisional credit you can take up to 45 calendar days from the date of notification of the alleged error to complete your investigation and either make the provisional credit final or revoke the provisional credit. In the case of any of the following, you can take up to 90 calendar days from the date of notification of the error instead of 45 calendar days:

the EFT was not originated in a state (per the Reg E definition of "state")
the EFT occurred within 30 days from the first deposit into the account
the EFT was a point-of-sale debit card transaction.

Keep in mind this time clock runs concurrently with the provisional credit time clock. It starts from the date you receive notice of the error, not from the date you make the provisional credit.

First published on BankersOnline.com 2/25/08