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Visa DC Dispute-Time Frame for Each Company?

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Question: 
Visa debit card dispute. A customer just noticed transactions that posted to their account. The customer is disputing three different companies. Do we figure the time frame each merchant? Or would the liability be on consumer because they did not notify us to block their account on the first transaction?
Answer: 

There are two seperate questions to be answered. First, the consumers liability under Reg E 1005.6 is based on when the cardholder learned of the theft of their VISA card, not when the first transaction posted to their account. (Also note if the customer has their card in their possession and the fraud is the result of a counterfeit card, the $50/$500 liability tiers do not apply.) Reg E treats this dispute as a single claim for all three transactions. Note the language in 1005.6(b): Limitations on amount of liability. A consumer's liability for an unauthorized electronic fund transfer or a series of related unauthorized transfers shall be determined as follows...

Your provisional credit timeframes and investigation timeframes are based on the date your customer notified you of the error, not the date the transactions posted to the account. Since this is a VISA card, provisional credit is required within 5 business days of your cardholder's notification, and under Reg E your investigation must be completed 90 calander days from the date of notification. Under VISA's Zero Liability protection, if the transactions are proved to be unauthorized, your cardholder's liability will be $0.

First published on BankersOnline.com 2/18/13

First published on 02/18/2013

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