Liability for MasterCard Debit Card Dispute (Reg E)

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Question:

We issue MasterCard debit cards. If a customer disputes a transaction where a PIN was used per Reg E and MasterCard, can we assess the $50.00 dollar liability? Card wasn't lost or stolen.

Answer:

MasterCard's Zero Liability does not apply to PIN-based transactions. The $50.00 liability in Reg E 1005.6(b)(1) applies to transactions performed by a lost or stolen access device provided that it is an "accepted access device." In the event the physical card is stolen and the PIN used, the cardholder is liable for $50.00. If the card was skimmed and a copy was used to make the PIN transaction, the copy is not considered an accepted access device. The cardholder would have no liability unless they do not provide timely notice as defined in 1005.6(b)(3).