What Regulation E requires when a consumer disputes an electronic fund transfer, where the clocks are, and what an automated dispute workflow does at each step.
Regulation E is the rule that governs what a US institution must do when a consumer reports an error on an electronic fund transfer: a debit card purchase, an ATM withdrawal, an ACH debit, a person-to-person payment.
It sets the clocks. The consumer has 60 days from the statement that first shows the error to report it. The institution must investigate promptly. If it cannot finish within 10 business days (20 when the disputed transfer was made within 30 days after the account's first deposit), it must provisionally credit the consumer's account, and it may then take up to 45 calendar days (90 for a point-of-sale debit card transaction, a transfer initiated outside the United States, or a transfer made within 30 days after the first deposit). When the investigation is complete, the institution reports the result within three business days, and if the error is confirmed, corrects it within one business day.
Every one of those clocks starts from an event in the case: the notice of error, the provisional credit, the end of the investigation, the finding and, if it comes to it, the debit of the credit. That is why Reg E compliance is a workflow problem before it is a policy problem. A workflow that carries the clocks knows, for every open case, which day it is on and what has to happen before which date. A spreadsheet does not.
Yes, when the payment goes to or from a consumer account. A payment the customer did not make is an unauthorized electronic fund transfer and gets the full error resolution process. That includes a payment made by someone who tricked the customer into sharing a login or a one-time code. A payment the customer sent themselves, even one they were deceived into sending, is generally not an unauthorized transfer under the rule; the institution still has to investigate the customer's notice and report the result. This is why authorized scam claims are worked differently. AdjustmentHub has a dispute workflow for Zelle claims and tracks their Reg E clocks. It has no direct connection to Zelle.
Yes, in most cases. ACH debits and credits to a consumer account are electronic fund transfers, including a check a merchant converts into an ACH debit. Two exceptions catch desks out: automatic transfers between accounts at the same institution, and recurring preauthorized transfers at an institution with assets of $100 million or less, which sit outside most of the rule. Business accounts are outside the rule. The Nacha Operating Rules add their own return windows on top of the Reg E clocks.
For a consumer, 60 days from the statement under Regulation E. Under the Nacha Operating Rules, the institution can return an unauthorized consumer debit, or one that does not match what the customer authorized, so that it reaches the originator's bank by the opening of business on the banking day after the 60th calendar day following settlement. It needs the customer's signed Written Statement of Unauthorized Debit. These returns do not cover disputes about goods or services. After that window the return route is closed, though the institution may still have a warranty claim against the originator's bank within Nacha's time limits. The Reg E obligation to the customer does not depend on either.
Generally not. A transfer through Fedwire or a similar wire system used mainly between banks or businesses is not an electronic fund transfer under Reg E, so a wire claim is handled as a trace and recall under the wire rules. Two exceptions: an ACH credit that moves the funds into the consumer's account after a wire is covered, and a consumer's wire to another country is a remittance transfer, with its own error rules in Subpart B of Reg E.
Yes. A direct deposit is an electronic credit to a consumer account, so a deposit that is missing, short or posted to the wrong account can be reported as an error under the rule. The institution investigates and reports the result, even if the cause turns out to sit with the payer.
Yes. Debit card purchases and ATM withdrawals are electronic fund transfers from a consumer account. Prepaid accounts are covered under the rule's prepaid provisions, with different timing for when the 60 days start. For a prepaid account that is not a payroll card or government benefit account, the error resolution and liability rules do not apply until the institution has verified the customer's identity.
No. Credit card billing errors and fraud are Regulation Z, which has its own clocks, and under Regulation Z the customer's notice has to be in writing. A debit card is Reg E.
No. The rule covers accounts held by a consumer for personal, family or household purposes. An institution may choose to give business accounts similar treatment by policy; the regulation does not require it.
Payments by check (a check a merchant turns into an ACH debit is covered), transfers through Fedwire and similar wire systems, credit card transactions (Regulation Z), transfers on business accounts, most securities and commodities transfers, automatic transfers between accounts at the same institution, some one-off phone transfers, and recurring preauthorized transfers at institutions with assets of $100 million or less.
A consumer's notice to their institution that something is wrong with an electronic fund transfer: a transfer they did not make, a wrong amount, a missing transfer, a bookkeeping error, the wrong cash from an ATM, or a request for information about a transfer. A notice that arrives within 60 days of the statement, identifies the account and says why the customer thinks there is an error starts the clocks in the table above. It can be given by phone.
The consent a consumer gives before an institution may charge overdraft fees on one-time debit card and ATM transactions. It is part of Regulation E but not part of the dispute process.
Calendar days. The 10 and 20 day periods for provisional credit are business days; the 45 and 90 day periods for finishing the investigation are calendar days.
No. The institution must begin its investigation promptly when it receives an oral or written notice of error, and may not delay starting or finishing it while it waits for information from the customer. Nor can it require the customer to contact the merchant first.
Yes. A notice can be oral or written. The institution may ask for written confirmation within 10 business days of an oral notice, but the investigation runs from the oral notice. If the confirmation does not arrive, the institution need not give provisional credit, but it still has to investigate on time.
Under Regulation E it depends on how quickly the customer tells the institution: up to $50 if they report a lost or stolen card or access device within two business days of learning of it, up to $500 after that, and potentially more for unauthorized transfers that appear on a statement and are not reported within 60 days of it.
It has not complied with the rule, and the missed step still has to be done. The rule sets the deadlines; it does not say the credit becomes final on its own when one is missed.
AdjustmentHub · Provisional credit under Reg E, explained · Why institutions automate disputes
