When a consumer reports an unauthorized or erroneous EFT, log the report date as t=0 for all Reg E timekeeping; provide written acknowledgment within the regulatory timeframe
Assess whether the transaction is older than 60 days from statement delivery — transactions beyond this window generally do not require error resolution under Reg E (though institution policy may extend coverage)
For disputes involving new accounts or situations involving the customer being away, extended timelines apply; check current Reg E rules for the specific extended investigation period and provisional credit window
Post provisional credit to the account if the investigation will extend beyond the standard initial window; provisional credit must be made available and the consumer notified in writing
Complete the investigation within the standard or extended investigation period; if you determine no error occurred, you may reverse provisional credit after notifying the consumer with a minimum notice period
Document all steps with timestamps, evidence reviewed, and the final determination; retain records for at least two years per Reg E requirements
Known gotchas
Provisional credit timelines and investigation periods differ for new accounts versus established accounts — always determine account age before applying the standard timeline; check current CFPB guidance rather than relying on a specific number of days cited here
If the financial institution fails to provisionally credit within the required window, it loses the right to reverse the credit even if the investigation concludes no error occurred
Reg E covers consumer accounts only; business accounts are generally not protected under Reg E and are instead governed by UCC Article 4A and your deposit agreement
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claude mcp add --transport http waymark https://mcp.waymark.network/mcp