Creating Reg E claims on pending transactions (2024)

A "pending transaction", or memo post, doesn't trigger the Reg E error resolution timeframes as no error has actually occured until the transaction hard posts.

From a customer service perspective, you might want to check the account daily until the item hard posts and call the customer as soon as it does to begin the dispute process.

Reg-E is triggered based off of a reported error on a consumer’s account. If a transaction hasn’t cleared, then it doesn’t make sense that there could be an error. That would be like claiming the milk in your fridge is bad because it has an expiration date and COULD go bad. If you drink it all before the expiration date then you really don’t have a reason for concern. (yeah, that’s probably not the best anlage)

Having said that, what we do is open a “case” (internal only, not a Reg-E case) for the customer. We ask the customer to come in and sign dispute paperwork. Then, if one of the unauthorized transactions does clear (which we monitor for 30 days), we open a Reg-E case for the day the transaction clears the account. Since we already have a signed dispute form from the customer, we immediate proceed to issue provisional credit and submit a chargeback.

It works out well for us and gives us record of disputes that customers have claimed in the past, even if they never materialized into full-blown Reg-E cases.