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Extending Reporting Time Limits

Answered by: 

Question: 
Is the Pandemic a qualifying factor under Regulation E Extension of Time Limits? Is there a list of situations that qualify?
Answer: 

Regulation E specifically calls out extended travel and hospitalization as two situations where the bank must allow for extended notification, because frankly the customer would not be able to notify you if they were in a coma. These two situations are not intended to be all-inclusive, or the only situations where the bank must allow for a longer notification period.

No, there isn’t a list of all situations. Banks must consider the facts of why the consumer customer is late in reporting the unauthorized activity and determine if it meets the spirit of the law.

This is an area where more questions will benefit both the bank and the customer. If you don’t ask the right questions, you might not have enough information to know your bank must apply the extension.

Here is a situation I can easily see happening given current events:

Customer is in isolation with 3 young children and does not have internet to access her statements online; she used to access her statements at work, but she was laid off mid-March. She is still in possession of her card and no one has had access to it. Since she could not access the statements, she had no way of knowing the transactions occurred until the bank calls to let her know that her account is overdrawn.

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Learn more about Rayleen Pirnie’s webinar COVID-19 Means Increased Risk for Banks

First published on 04/19/2020

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