by Randy Carey:
No. The physical debit card was not lost or stolen.
by Andy Zavoina:
If the bank sends me a debit card and I do not receive it, it was not in my possession or even an activated device. Like a cloned card, I may not have even know it was out there. In that case I am not responsible for its mis-use and in the case of .6(b)(3) the first two tiers of liability. Remember that Reg E is a consumer protection regulation and tends to favor the consumer. It certainly does in this case and it's not unreasonable.