You still are required to provide the provisional credit under section 1005.11 of Regulation E. It may mean that the account will have to be reopened or that you'll have to open another account for the purpose of allowing the consumer full use of the provisional credit amount pending completion of your investigation. You are not required to issue a replacement debit card.
Provisional Credit-Wallet Stolen/ATM Withdrawals
A customer disputes ATM withdrawals because his wallet was stolen. In the wallet was his PIN and debit card. Due to all of the customers personal information that was stolen, the customer closed out their checking account. Normally, we would give provisional credit to the account that was debited. The customer has no other accounts with us now. How do we issue a provisional credit in this case?
First published on 12/16/2018