Reg E workflow
The Reg E case lifecycle — from dispute notice to resolution
Every Reg E dispute follows the same path: intake, deadline calculation, investigation, letters, provisional credit decisions, and a final resolution that can survive examiner scrutiny. This page walks through each step and how KohltSoft handles it.
Deadline calculation
The investigation deadline depends on the dispute type and the age of the account. Getting the wrong deadline path is a compliance finding. KohltSoft calculates the correct path from intake and tracks every related notice deadline.
Learn more about Reg E deadline calculation10 business days
Standard ACH and debit card disputes
The bank must complete its investigation within 10 business days of receiving the notice. Provisional credit is not required if the investigation concludes within this window.
45 calendar days
POS and foreign-initiated disputes
If the bank cannot complete the investigation within 10 business days, it may extend to 45 calendar days for POS transactions or transactions initiated in a foreign country — but must provisionally credit the account within 10 business days.
20 business days
Disputes involving accounts open fewer than 30 days
For new accounts, the initial investigation window extends to 20 business days before provisional credit is required, with the full investigation extended to 90 calendar days for POS or foreign-initiated disputes.
90 calendar days
New account POS or foreign-initiated disputes
The 90-day path applies when both conditions are present: the account is new (open fewer than 30 days) and the transaction is a POS or foreign-initiated dispute.
Required letters
Reg E mandates written notices at specific points in the investigation. Exam findings often come from letters sent late, sent with missing required content, or — most commonly — letters that cannot be produced when asked. KohltSoft generates each letter from the case record and stores it with proof of send.
Confirmation of receipt
Timing: Within 10 business days of receiving the dispute notice
The bank must acknowledge receipt of the error notice. This starts the documentation trail and establishes the date the investigation clock began.
Provisional credit notice
Timing: On or before the date provisional credit is issued
Required only when provisional credit is issued. Must state the amount of the credit and the date the funds are available. Failure to send this notice is itself a Reg E violation.
No-error explanation
Timing: At the conclusion of the investigation
When the bank determines no error occurred, it must notify the consumer in writing — including a statement of the consumer's right to request the documents the bank relied on and a statement that provisional credit, if issued, will be reversed.
Reversal notice
Timing: At least five business days before the debit date
If provisional credit will be reversed, the bank must give the consumer five business days advance notice before debiting the account. This notice and its timing are frequently cited in exam findings.
Final resolution letter
Timing: At the conclusion of the investigation
When the bank concludes the investigation in favor of the consumer, it must notify the consumer in writing of the outcome and any actions taken.
Provisional credit
Provisional credit has documentation requirements at every stage. KohltSoft tracks the full credit lifecycle — issuance, notification, finalization, and any reversal — in the case record.
Issuance
Credit amount, date issued, and the investigation window that triggered the requirement are recorded at the time of issuance.
Notification
The provisional credit notice is generated from the case record and sent to the consumer. Date and method of notification are logged.
Finalization
At the conclusion of the investigation: credit finalized (error confirmed), adjusted (partial error), or reversed (no error) — with documented basis and required advance notice for reversals.
Audit trail
The evidence package an examiner expects includes: when the dispute was received, what deadline path applied, every letter sent with proof of send, all provisional credit decisions and their timing, the investigation notes and supporting documents, and the final resolution with documented basis. KohltSoft assembles this automatically from actions taken in the system.
What gets preserved in the audit package
- Dispute intake record — date received, reported amount, transaction details
- Calculated deadline path — which window applies and why
- Every case action with timestamp and responsible party
- All required letters with full text and proof of send
- Provisional credit history — issuance, notification, and finalization
- Investigation notes and supporting documents attached
- Final resolution decision with documented basis
See the workflow in your cases
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