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Submits Dispute Orally & Not Written: Deny Claim?

Question: 
If we disclose to our customers in the initial disclosure that all Reg E disputes must in writing and the customer orally submits a dispute, but doesn't follow up in writing, can we deny the claim?
Answer: 

by Jim Bedsole:

No. The only thing you gain in that scenario is that you don't have to provide provisional credit in order to take advantage of the longer investigation period (45/90 calendar days rather than 10/20 business days) if the customer doesn't provide written confirmation. But you still have to investigate and make a determination based on the investigation in response to the oral notice of alleged error.

Answer: 

by David Dickinson:

You can't take people's rights away from them. Reg E states customers can make oral claims of Reg E disputes. [§1005.6(b) and §1005.11(b)(1)]. You can ask customers to put disputes in writing, but you shouldn't tell customers that all Reg E disputes must be in writing.

First published on 07/22/2018

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