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Procedure for Issuing Provisional Credit (Dispute)

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According to Regulation E, financial institutions have 10 business days from their date of notification to issue provisional credit for a dispute. In cases where the customer closes their deposit account before their provisional credit is issued, what is the proper procedure for issuing this credit? Should we reopen the account and explain to the customer that we have rights to withdraw that credit for up to 45 days?

Except for the 45 days part of your solution, you're on the right track. You must provide the provisional credit if the customer qualifies for it and you aren't able to complete the claim investigation and final adjustment within 10 business days (20 in limited cases for new accounts). That will require that you reopen the account (or open a new one for this purpose). I think it's wise to inform the consumer that depending on the outcome of the investigation, the provisional credit could be revoked or changed within 45 days (90 days for debit card transactions or for transactions originating outside the U.S. and its territories).

Once the provisional credit is given and until you've finalized, reversed or adjusted it to close the investigation, the customer must have full use of those funds, and he or she can draw the account down to a zero balance during that period. I suggest that you not allow your system to close the account out, however, until after you've finalized the investigation and any adjustments to the account.

First published on 8/15/11

First published on 08/15/2011

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