Regulation E rules

To ensure compliance with Reg E rules and timely resolution of customer cases, complete the investigation of a case in Smart Dispute Agentic Automation within the specified timeframes. The bank must not violate Reg E rules.

Smart Dispute Agentic Automation identifies the duration between the notice of error and the date of the first deposit to the account. If the duration is more than 30 days, the bank must complete the investigation within 10 business days of the notice of error. If the investigation cannot be completed within 10 business days, the bank must grant provisional credit to extend the investigation. The bank can take up to 45 days from receipt of the notice of error to investigate and determine whether an error occurred.

If the duration is less than 30 days, the bank must complete the investigation within 20 days of the notice of error. If the investigation cannot be completed within 20 days, the bank must grant provisional credit to extend the investigation. The bank can take up to 90 days from receipt of the notice of error to investigate and determine whether an error occurred, provided the bank issued provisional credit in compliance with the rules for provisional credit.

If the bank does not receive the written statement of dispute within the 10/20-day period from the customer, a provisional credit is not required. However, the 45-day rule still applies.

The bank can take up to 90 days in place of 45 days under certain conditions:

• The transaction was not initiated.
• The transaction resulted from a point-of-sale debit card transaction (excludes ATM transactions).
• The transaction occurred within 30 days after the first deposit to the account occurred.

Complete the investigation of a case in Smart Dispute Agentic Automation within the timeframes outlined in Reg E to resolve the customer's case on time and ensure that the bank complies with Reg E rules. Smart Dispute includes rules for managing the application of provisional credit in accordance with Reg E rules.

• To comply with Regulation E rules and resolve customer cases on time, the bank must complete the investigation of a case in Smart Dispute Agentic Automation within the specified timeframes. Smart Dispute determines the correct time frames by identifying when the first deposit to the account occurred.
• If duration between the first deposit to the account and notice of error is more than 30 days, the bank must complete the investigation within ten days of the notice of error. If this is not possible, the bank must grant provisional credit to extend the investigation.
• If duration between the first deposit to the account and notice of error is less than 30 days, the bank must complete the investigation within 20 days of the notice of error. If this is not possible, the bank must grant provisional credit to extend the investigation.
• If the bank follows the 10-20 business day rule and the case resolution is not complete within 10-20 days, the service-level agreement (SLA) triggers an action to grant provisional credit to each transaction covered under Reg E in the claim. Smart Dispute provides a business configuration point that allows the bank to decide whether to grant immediate provisional credit or follow the 10-20 business day rule. However, if the bank requires but has yet to receive written confirmation of an oral notice of error within 10-20 business days, the bank is not obligated to provide provisional credit.
• Regardless of whether immediate provisional credit has been granted or whether the bank applies for the provisional credit in line with the ten-day or 20-day rule, the bank must proceed with the investigation upon notice of an error. The case status changes to Granted if provided immediately or to Deadline if the bank chooses to wait until the end of the 10-day or 20-day period.
• Smart Dispute generates a notification for the customer within two business days after granting provisional credit of the amount and the initial date of the provisional credit. The notice also informs the customer that they can fully use the funds during the investigation. The verbiage of the notice can be configured to use the bank's policy. Before providing provisional credit, validate the Provisional Credit flag. If the provisional credit is already provided to the customer as part of automatic provisional credit the flag would be Yes. The system provides provisional credit to eligible transactions only if the value of the Provisional Credit flag is No, as automatic provisional credit is not provided for the dispute case. This process applies to all US deposit account transactions, for example, debit card, ATM, ACH, Zelle, and any other future deposit account electronic payment types.

Implement the Reg E attestation in the Model Workflow to allow authorized users to provide provisional credit to customers based on verbal or written attestations. In this process, the issuing bank can evaluate verbal attestations for transactions covered by Reg E at the dispute case level and automatically provide provisional credit upon completion of the SLA by the system.

1. In the Collect supplemental information screen, respond to the new question for verbal attestation, Do you attest that the selected transaction(s) were debited from your account and were not authorized or were processed in error? by selecting either Yes or No.
   1. If you select Yes, the system updates the value of the Customer attestation received field to Yes and displays it in the footer on the Regulation tab for all the dispute cases under the claim that are applicable for Reg E.
   2. If you select No, you must complete the written attestation form, and then submit it to the issuing bank. The system displays the information message as In order to receive provisional credit, please return this form within 10 business days from the date on the letter or email.
2. If a verbal attestation is denied by customer then written attestation becomes mandatory. The agent can capture the Reg E written attestation by processing the  Process Reg E Provisional Credit assignment once the attestation duly signed by cardholder is received. When agent submits the Process Reg E Provisional Credit assignment, the Reg E written attestation is considered as captured and the system updates the Customer attestation received field to Yes  on the  Regulation  tab. The dispute case is moved back to the Reg E Provisional Credit assignment to continue processing for the Reg E provisional credit

Configuration

Reg E Attestation configuration is enabled (Yes)

The customer will not receive Reg E provisional credit upon completion of the service-level agreement (SLA), if the bank does not receive the attestation within the 10-20day timeframe (Reg E PC Due Date).

Reg E Attestation configuration is disabled (No)

The customer will receive Reg E provisional credit even if the bank does not receive the attestation within the specified 10-20-day timeframe (Reg E PC Due Date).