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Reg E Dispute from Closed Account

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Question: 
I had a member who filled out a Reg E dispute for a subscription that was coming out of her account for months. After she filed the dispute she closed out her account. Does Reg E say I have to file the dispute? I don't have an account/membership to give her access to the funds or pull from if this is a valid charge.
Answer: 

In that Reg E is a consumer protection regulation, the claim is not going to be negated because the consumer was so upset with the bank and the claim that the account was closed. Reg E does indicate the claim is settled by crediting the consumer's account. If that account is gone, I would open a new account with them, without fees to the consumer unless they use it, or provide them with a cashier's check clearly marked as a claim payment and if it is final or provisional.

The consumer should have full use of the funds either way.

First published on 11/24/2019

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