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Settling Reg E Claims

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Question: 
When a Reg E claim is received which consists of several transactions at various merchants, is the claim settled and responded to after the last one is investigated and finalized or as each transaction within the claim is investigated and finalized?
Answer: 

You would be well-advised not to lump such claims together for your error-resolution process, even if some of them might have common elements. You might benefit from looking at them together to create a context for the claims and look for patterns that might help you decide whether the customer's claim is legitimate. You cannot depend on merchants to act together in their responses to the individual claims, so you should not work the claims as a single case.

Don't take this as license to put a separate liability limit on your customer for each "case," however. Although you might need to keep the transactions separate so that you can manage final resolution separately, your customer is still protected by one overarching section 205.6 limit for unauthorized transfers if they are related to a single compromise of an access device, for example.

First published on BankersOnline.com 11/10/08

First published on 11/10/2008

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