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Reg E ATM dispute - Provisional and final credit

For a REG E ATM Dispute we have a customer filing a claim for $700. She filed a police report and states she didn't know the individual. We have proof on video that she came into the bank with the individual in question. The customer isn't responding to our calls and we would like to know if we still need to give provisional credit and/or final credit if this this is the case.

by David Dickinson:

Sounds like you caught the customer in a lie. However, could the individual have coerced or forced her into the bank? I would not provide provisional or final credit until I was able to gain more information. In the mean time, I would not treat this as an "unauthorized" EFT by relying on the definition found in §1005.2(m):

“Unauthorized electronic fund transfer” means an electronic fund transfer from a consumer's account initiated by a person other than the consumer without actual authority to initiate the transfer and from which the consumer receives no benefit. The term does not include an electronic fund transfer initiated:

By a person who was furnished the access device to the consumer's account by the consumer, unless the consumer has notified the financial institution that transfers by that person are no longer authorized;

With fraudulent intent by the consumer or any person acting in concert with the consumer;


by Dan Persfull:

She filed a police report and states she didn't know the individual.

Sounds like she filed a false police report also. You may want to talk to your attorney about turning over your evidence to the police.

First published on 06/10/2018

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