Swipe Happens
A customer reports someone stole their debit card and made purchases at a gas station before the card was blocked. Authorized or not?
Unauthorized. The customer did not authorize the transactions, so this is an unauthorized EFT subject to Reg E investigation.
What should the customer do as soon as they discover unauthorized activity?
Notify the bank immediately.
Within how many business days must the bank generally complete its investigation before provisional credit may be required?
10 business days.
A customer's debit card is stolen and used to make purchases at a local department store. Covered or not covered?
Covered.
A customer notices unauthorized debit card transactions and reports them to the bank the same day they learn their card was stolen.
Tier 1
A customer purchased furniture with their debit card. The furniture never arrived. Authorized or not?
Authorized. This is a merchant dispute regarding goods or services—not an unauthorized EFT under Reg E.
How many business days does the bank generally have to complete its investigation before provisional credit may be required?
10 business days.
What must generally be provided to the customer if the investigation isn't complete within 10 business days?
Provisional credit
A customer writes a check that is altered and cashed for a larger amount. Covered or not covered?
Not Covered.
A customer learns their debit card was stolen but waits five business days before notifying the bank.
Tier 2
A customer gave their debit card and PIN to their adult son to buy groceries. Instead, he withdrew $800 from an ATM for himself. Authorized or not?
Not unauthorized. Because the customer voluntarily gave the son authority to use the card and PIN, the transaction generally is not considered unauthorized under Reg E.
Just because the customer didn't like how the money was used doesn't automatically make it unauthorized.
What must generally happen by the end of the 10th business day?
The bank must provide provisional credit (if the investigation qualifies) so the customer has access to the disputed funds while the investigation continues.
Within how many business days after conclusion of investigation must the customer be notified of the results?
3 business days.
A customer sends money through a peer-to-peer payment app after being tricked by a scammer posing as the bank. Covered or not covered?
Not covered.
A customer doesn't review their statement and reports unauthorized transactions 75 days after the statement showing the first unauthorized transaction was sent.
Tier 3
A customer notices a streaming service has charged their debit card every month after they forgot to cancel their subscription. Authorized or not?
Authorized. The customer originally authorized the recurring payments. This is a cancellation issue with the merchant, not an unauthorized EFT.
How many business days does the bank have to notify the customer after completing its investigation?
3 business days.
True or False: "All Reg E deadlines are measured in business days."
A customer notices an unauthorized ACH withdrawal from their checking account. Covered or not covered?
Covered.
A customer gave their debit card and PIN to a friend to buy groceries. Instead, the friend withdrew $1,000 for personal use.
No Tier. This is not an unauthorized EFT under Reg E because the customer voluntarily gave the friend authority to use the card.
A fraudster convinces a customer over the phone to transfer money using a peer-to-peer payment app because they claim the customer's account is at risk. Authorized or not?
Authorized. The customer initiated the payment themselves, even though they were deceived. Because the transfer was authorized by the consumer, it is not considered an unauthorized EFT under Reg E.
This is one of the biggest Reg E misconceptions. Being tricked or scammed does not automatically make a transaction unauthorized under Reg E if the consumer initiated the payment.
What's the first date we ask on our dispute form?
When did you first learn of the theft or unauthorized transaction?
A customer notices an unauthorized EFT on their statement but doesn't notify the bank until 75 days after the statement was sent. What important Reg E deadline has the customer missed?
The 60-day statement notification deadline.
A customer purchased airline tickets with their debit card. The airline canceled the flight and refuses to issue a refund. Covered or not covered?
Not Covered. This is a dispute over the quality or delivery of goods/services—not an unauthorized electronic fund transfer. The customer must resolve the issue with the merchant.
A customer reports unauthorized debit card transactions one business day after learning their wallet was stolen, but also mentions they ignored statements for three months that showed earlier unauthorized transactions.
Both Tier 1 and Tier 3. The report of the stolen card is timely (Tier 1), but failing to report unauthorized transactions shown on statements for more than 60 days may result in Tier 3 liability for subsequent unauthorized transactions that occurred after the 60-day period.