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Debiting provisional credit after Reg E claim closed

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If the bank has already closed out a dispute claim because the 90-day time frame was up and provisional credit was made final, the bank cannot take funds back if the merchant provides credit after that time?

That is correct. If the deadline approached the bank had to complete the process to comply with the reg. If the merchant refunds the consumer after that, the bank can ask for the return of the funds because there is no intent in the law to have consumers profit from a claim at the expense of the bank. The intent is to make the consumer whole. But there is no allowance for a bank to debit a consumers account AFTER the claim is finalized. The bank is authorized to debt the provisional credit and that ability extends only for duration of the claim.

First published on 08/29/2021

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