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Government watch
Reg. E Error Resolution: Everyone’s Business
The timing of when a notice of error is received is critical to everything that follows, because the clock toward provisional credit starts with that first contact. And, if you’re second or third in line in the investigation process, the clock doesn’t start when you received the notice, it started with the consumer’s first contact. Also, if you require written confirmation of an error allegation, the clock starts with the first notification, not when you receive written notice.
• Initial disclosure. The pre- paid issuer likely provides
the cardholder agreement to consumers, but the agreement is relevant to TPSPs because your processes and proced- ures must match what is rep- resented in the cardholder agreement. For example, if the agreement implies that all error allegations will be handled under the Reg. E error resolu- tion process, then all allega- tions must conform—even if
fiRst contact counts
the error allegation technically doesn’t fall under Reg. E.
• Customer service scripts. Make certain your scripts don’t inad- vertently violate Reg. E, because what you say to consumers and how you say it matters and could make the difference between compliance and noncompliance. For example, your scripts may
not include a statement such as: “We require you to file a police report before we can launch our investigation.” But, you could say: “We recommend you file a police report, and it would help our investigation if you provide it to us. Not having the report, however, will not delay the start of our investigation nor influence the results of our investigation.”
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