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PayPal was used – is this our Reg E claim?

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What if the customer says that they don’t have a PayPal account? And they don’t know how PayPal got their information, can you deny the claim and have them contact PayPal?

The Reg has no guidance on this other than § 1005.14. I would use this to my advantage. PayPal doesn’t hold the account and did issue an access device for use. The bank has no agreement with PayPal for access, so I would push them to PayPal as they have the facts of the transfers which the bank does not. In the interest of customer service I might ask the customer to let us know what is said, but as the Reg is

written, the claim is on PayPal. If the bank opts to entertain a claim, it should do so consistently with all similar claims.

First published on 11/28/2021

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