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How do Reg E disputes work?

By Ben Tabas, Intrica Research · Updated · US

Answer

A Reg E dispute starts when a consumer reports an error on an electronic fund transfer, and the bank or fintech must investigate it under 12 CFR 1005.11. The current regulation on the CFPB site, checked Oct. 28, 2026, gives the institution 10 business days to decide, or up to 45 days if it provisionally credits the account within those 10 business days.

The timeline

  1. The consumer gives notice no later than 60 days after the institution sends the statement that first shows the error (12 CFR 1005.11, checked Oct. 28, 2026).
  2. If the notice was oral, the institution may ask for written confirmation within 10 business days.
  3. The institution investigates and decides within 10 business days, or 20 business days for a transfer made within 30 days after the account's first deposit.
  4. If it needs longer, it provisionally credits the disputed amount and may take up to 45 days. The window is 90 days for point-of-sale debit card transactions, transfers not initiated within a state, and transfers in a new account's first 30 days.
  5. It reports the result to the consumer within three business days after finishing the investigation.
  6. If it finds an error, the CFPB's consumer guidance, last modified Aug. 31, 2026, says it must correct it within one business day. If it finds no error, it must give written notice before it takes back a provisional credit.

How much the consumer can lose on an unauthorized transfer

  • Up to $50 if the consumer reports a lost or stolen card or code within two business days of learning of it (12 CFR 1005.6, checked Oct. 28, 2026).
  • Up to $500 if the consumer reports it later than two business days.
  • Unlimited for transfers that happen more than 60 days after the statement showing the first unauthorized transfer was sent, if the institution shows timely notice would have stopped them.

What a fintech team needs in place

  • An intake path that accepts oral and written disputes and timestamps the notice.
  • A ledger that can post and reverse provisional credit by account, with an audit trail.
  • Letters for results, provisional credit and reversals that go out inside the rule's deadlines.
  • A clear split of duties with the sponsor bank, written into the program agreement.

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Sources

  1. 12 CFR 1005.11, Procedures for resolving errors · Consumer Financial Protection Bureau, Oct. 28, 2026Supports: Checked Oct. 28, 2026: the 60 day notice window and the 10, 20, 45 and 90 day investigation periods.
  2. 12 CFR 1005.6, Liability of consumer for unauthorized transfers · Consumer Financial Protection Bureau, Oct. 28, 2026Supports: Checked Oct. 28, 2026: the $50, $500 and unlimited liability tiers.
  3. How do I get my money back after I discover an unauthorized transaction or money missing from my bank account? (Ask CFPB) · Consumer Financial Protection Bureau, Aug. 31, 2026Supports: The one business day correction, the three business day report, and written notice before a provisional credit is removed.

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General information, not legal advice.

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