Page 82 - Pay Magazine s2014

Government watch
Reg. E Error Resolution: Everyone’s Business
10th daY Reg. e eRRoR Resolution date chaRt novembeR /decembeR 2014
SyStem Date
Mon 11/03/14 Tues 11/04/14 Wed 11/05/14 Thurs 11/06/14 Fri 11/07/14 Mon 11/10/14 Tues 11/11/14 Wed 11/12/14 Thurs 11/13/14 Fri 11/14/14 Mon 11/17/14 Tues 11/18/14 Wed 11/19/14 Thurs 11/20/14 Fri 11/21/14 Mon 11/24/14 Tues 11/25/14 Wed 11/26/14 Thurs 11/27/14 Fri 11/28/14 Mon 12/01/14 Tues 12/02/14 Wed 12/03/14 Thurs 12/04/14 Fri 12/05/14 Mon 12/08/14 Tues 12/09/14 Wed 12/10/14 Thurs 12/11/14 Fri 12/12/14 Mon 12/15/14 Tues 12/16/14 Wed 12/17/14 Thurs 12/18/14 Fri 12/19/14 Mon 12/22/14 Tues 12/23/14 Wed 12/24/14 Thurs 12/25/14 Fri 12/26/14 Mon 12/29/14 Tues 12/30/14 Wed 12/31/14
Reg. e 10th BuSineSS Day
18-Nov 19-Nov 20-Nov 21-Nov 24-Nov 25-Nov holiday 26-Nov 28-Nov 1-Dec 2-Dec 3-Dec 4-Dec 5-Dec 8-Dec 9-Dec 10-Dec 11-Dec holiday 12-Dec 15-Dec 16-Dec 17-Dec 18-Dec 19-Dec 22-Dec 23-Dec 24-Dec 26-Dec 29-Dec 30-Dec 31-Dec 2-Jan 5-Jan 6-Jan 7-Jan 8-Jan 9-Jan holiday 12-Jan 13-Jan 14-Jan 15-Jan
source: Patti Joyner Blenden, Founder and President, Financial Solutions. Reprinted with permission.
considered received on Monday (“Day Zero”), and the10th business day is Nov. 18. (See chart at right.) It doesn’t matter that you received the notification outside of business hours, if you’re accepting notifica- tions electronically or you have 24-hour customer service, “busi- ness hours” aren’t relevant to when the error resolution clock starts ticking. Similarly, if you’ve asked
for written confirmation of an error, the consumer has until midnight (not your close of business) on
the 10th business day to provide that confirmation.
Other critical time requirements:
• The consumer must be notified of the provisional credit (including the posting date and amount) within two business days of the credit to his prepaid account.
• If, after the investigation, you determine the consumer is not owed the provisional credit, be- fore you can debit the provisional credit, he must be notified that debits to the account will be honored for five business days following the notice. (Alternatively, you may notify the consumer
five business days in advance of reversing the provisional credit.)
• If the investigation shows no error (or a different error) occurred, the consumer must be notified in writing within three business days of completing the investigation. (Certain informa- tion requirements must be part of the communication.)
• If the investigation reveals the consumer is owed the provi- sional credit, he must be notified of the finalization of the credit within three days after the investigation is complete.
• An identified error must be corrected within one business day, and the consumer must be notified of the correction within three business days.
• Documentation must be retained for two years.
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“Process” is the other aspect of Reg. E error resolution that’s tech- nical. You need a process to ensure that not only timing is correct, but the consumer is informed of pre- cisely what he is entitled to know. For example, the consumer must be informed of the following:
• He has full use of the provision- ally credited funds while the investigation is underway.
• He has the right to documenta- tion that supports the decision that there was no error.
• The outcome of the investi- gation, regardless of whether there was an error, and the documents relied on to make the determination.
Other aspects involve:
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PRoCess matteRs