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Reg E Investigation Time Frame for eCommerce

Regulation E extends investigation time frames to 90 days for POS transactions. Where do eCommerce transactions fit? Are they under the 45 or 90 timelines for investigation?

Answer from Brian: For Reg E purposes, "point of sale" means any purchase using the debit card whether signature based or PIN based. This is true whether the cardholder was present at the merchant location, using mail/phone, the internet, or a mobile device. The investigation time frame for all of these transactions is 90 days.

The only card based transaction that would have a 45 day investigation time frame is a domestic ATM withdrawal.


Answer from Andy: It isn't a specifically defined term so as Brian says, you use the broad meaning. While you may have an extended period to investigate, don't forget you are still paying provisional credit at 10 business days unless you have a new account exception. So while the bank has more time to investigate, the consumer gets provisional credit in a timely manner.

First published on 5/20/13

First published on 05/20/2013

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