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Unauthorized Activity Claim-Multiple Transactions

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A customer contacts the bank regarding unauthorized activity that includes a claim with multiple transactions. Does the customer need to be informed of the final results of the investigation within three (3) business days after determining the results for "each" transaction involved or after the bank compiles all the results within the one (1) claim?

Regulation E doesn't discuss how to handle multiple transaction claims. It does, however, make it pretty clear that you have an obligation to notify the consumer when you've made a decision, with the obvious intent that the consumer either obtains the adjustment credit and learns of it as quickly as possible or gets informed promptly when provisional credits are made final.

To delay your notification of the consumer until you've made the final decision on the last of several transactions (or run out of time on your 45/90 day clock) runs counter to the clear intent of the regulation.

My advice: Advise the consumer as if each transaction were the subject of an individual claim. Any convenience your institution gains by combining all the alleged errors into one claim should not result in any lessening of the consumer's protection under the regulation.

First published on 5/2/11

First published on 05/02/2011

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