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Reg. E Dispute - Investigation exceeds 90days

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Question: 
The bank had multiple customers who were victims of the massive debit card breach in late January. Customers notified bank of these unauthorized POS debit card transactions in early to mid February and provisional credit was given at that time. Our bank does not investigate these disputes, instead we send them to our processor who investigates these claims for us. Our processor is overloaded with such claims from many banks, so we still haven't heard back from them on most of the claims we sent to them for investigation. The ninety day investigation period has now been exceeded, but we still have not been notified of the outcome of the investigation. What do we need to do at this point, continue to wait or issue notices to these customers telling them the provisional credit is final (and take the loss on any dispute that once investigated isn't a valid claim)?
Answer: 

You have no alternative but to make the provisional credits final and notify your customers of that fact. Look in your contract with the third party processor to determine whether you have any sort of service level guarantee or other redress against the processor.First published on BankersOnline.com 7/20/09

First published on 07/20/2009

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