Reg E Investigation Deadlines: The 10-Day, 45-Day, and 90-Day Rules Explained

The three investigation windows under Regulation E

Regulation E gives banks three possible investigation windows, not one. The window that applies to a given dispute depends on two factors: the type of transaction and the age of the account at the time of the transaction.

Getting the window wrong is the most common Reg E exam finding. Banks that apply the 45-day POS path to standard ACH disputes, or that treat a new-account dispute as a standard case, produce deadline errors that examiners identify in the first case they pull.

10 business days — the standard window

For most disputes, a bank has 10 business days from the date it receives the written error notice to complete its investigation. This applies to standard debit card and ACH transactions on accounts that are more than 30 days old.

If the bank cannot complete the investigation within 10 business days, it must issue provisional credit to the customer and take up to 45 calendar days to finish. The provisional credit extension is not optional — a bank that extends without issuing provisional credit has produced a Reg E finding regardless of whether the investigation outcome favors the customer.

45 calendar days — POS and extended investigations

The 45-day window applies in two situations:

POS (point-of-sale) transactions — debit card transactions made at a merchant terminal where the card was present
Foreign-initiated transactions — transactions that originated outside the United States

When the 45-day path applies and the bank cannot complete the investigation on time, it extends to 90 calendar days rather than the standard 45 days.

When a bank issues provisional credit and extends its investigation, it must notify the customer within two business days of the extension.

90 calendar days — new accounts

If the error involves a new account — defined as an account that has been open for 30 calendar days or fewer at the time of the alleged error — the investigation window extends to 90 calendar days. Provisional credit must still be issued within 10 business days if the investigation is not complete.

New accounts represent a disproportionate share of exam findings because banks commonly apply the standard 10-day or 45-day path without checking account age at intake. A new account with a POS transaction still gets the 90-day window — the transaction type does not override the account age trigger.

What examiners measure

During a Reg E exam sample, examiners pull individual cases and measure the distance from the written notice date to the investigation completion date in business days, not calendar days. Federal holidays are excluded. Common findings include:

Wrong deadline path applied — treating a new-account dispute as a standard 10-day case, or applying the POS path to an ACH transaction
Business day miscalculation — counting calendar days instead of business days, or failing to exclude federal holidays from the count
Provisional credit not issued — extending the investigation past 10 business days without issuing provisional credit first
No written notice to customer — failing to document that the customer was notified of the extension and the expected resolution date

How KohltSoft handles deadline calculation

KohltSoft applies the correct deadline path at intake based on transaction type and account age. The system calculates the investigation deadline in business days, excludes federal holidays automatically, and triggers a provisional credit alert when a case approaches the 10-business-day threshold without resolution.

Every deadline calculation is logged with a timestamp, making the audit trail available for exam review without any manual reconstruction.

See the Reg E Deadline Calculator for a breakdown of each deadline path by transaction type, or request a demo to see how KohltSoft manages deadline tracking across your full dispute portfolio.