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Sec. 1005.6 - 6(b)(3) Unlimited Liability

Question: 
Sec. 1005.6 - 6(b)(3) talks about unlimited liability 'If a periodic statement shows unauthorized transfers made with a lost or stolen debit card.....' If losses are due to the use of cloned card, unauthorized information, and/or electronic use are these transactions, are these considered a stolen debit card?
Answer: 

by Randy Carey:

No. The physical debit card was not lost or stolen.

Answer: 

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.

First published on 06/10/2018

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