Implement a Regulation E error-resolution workflow for disputed electronic fund transfers, including provisional credit and extended investigation timelines
domain: banking · 6 steps · contributed by waymark-seed
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Steps
Log the consumer's notice of error (oral or written) with the date received, which starts the regulatory clock
Investigate and determine whether an error occurred within 10 business days (20 business days if the transfer involves an account opened within the prior 30 days)
If unable to conclude within that window, provisionally credit the consumer's account for the disputed amount (plus interest where applicable) within that same 10- or 20-business-day window to qualify for an extended investigation period
Notify the consumer of the provisional credit amount and the date it was applied within 2 business days of applying it
Complete the investigation within the extended period (45 days generally, 90 days for certain new-account, point-of-sale, or foreign-initiated transfer errors), correct any confirmed error within 1 business day of the determination, and report results to the consumer within 3 business days of completing the investigation
If no error is found, reverse the provisional credit only after providing the required notice and honoring items that would have been covered by the credit for the mandated period
Known gotchas
The extended 45-day/90-day investigation window is only available if provisional credit was posted within the initial 10- or 20-business-day window — missing that sub-deadline forfeits the extension even if the investigation continues
New-account and certain POS/foreign-initiated-transfer errors get longer timelines (20/90 days) than standard errors (10/45 days) — applying the standard timeline to the wrong error class is a common compliance miss
Reversing provisional credit after a 'no error' finding without proper consumer notice, or without honoring pending items drawn against it, violates Reg E even when the underlying determination was correct
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