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As it relates to Reg E claims, I need clarification:<ol><li>is an internet purchase considered a POS<li>is a telephone purchase considered a POS</ol>I'm trying to utilize the POS 90 day extension time period. The reg is not straight forward in this regard.

Answer by Randy Carey:I think it is pretty clear:

Paragraph 11(c)(3)—Extension of Time Periods
1. POS debit card transactions. The extended deadlines for investigating errors resulting from POS debit card transactions apply to all debit card transactions, including those for cash only, at merchants' POS terminals, and also including mail and telephone orders. The deadlines do not apply to transactions at an ATM, however, even though the ATM may be in a merchant location.


Answer by John Burnett:The one thing not specifically mentioned there is an internet purchase using the card. It is, however, a debit card transaction that qualifies for the extension.

First published on 8/18/08

First published on 08/18/2008

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