Regulation E: A Member Reported Fraud — Now What?™ | Free Frontline Quick Reference

A Member Says, “I Didn’t Make This Transaction.” Now What?The first few questions matter.Was it a debit-card transaction? ATM withdrawal? ACH? P2P transfer? Did the member initiate the payment themselves—or did someone obtain their credentials and initiate the transaction?Regulation E: A Member Reported Fraud — Now What?™ gives bank and credit union frontline employees a practical framework for handling these conversations without prematurely deciding whether a claim will be approved or denied.LISTEN → IDENTIFY EFT → CAPTURE FACTS → FOLLOW PROCESS → ESCALATE / DOCUMENTWHAT'S INSIDEIdentify the Transaction Debit-card transactions ATM withdrawals ACH transactions Electronic account transfers Certain P2P/mobile transfers Recurring electronic debits Understand the Fraud QuestionThe guide helps employees distinguish between:Consumer-authorized paymentsandEFTs initiated by someone else without actual authorityIt also addresses an important situation where a fraudster obtains account-access information through deception and subsequently initiates the EFT.NOTICE OF ERROR — WHAT STARTS THE CLOCK?Frontline employees receive practical reminders covering: Oral and written notices The general 60-day notice window Capturing the member's report promptly Written-confirmation procedures Why the investigation shouldn't simply wait for paperwork REGULATION E TIMING AT A GLANCE10 BUSINESS DAYSGeneral initial investigation/determination period45 CALENDAR DAYSGeneral extended investigation period when applicable requirements are satisfied20 BUSINESS DAYSApplicable initial period for certain EFTs involving qualifying new accountsUP TO 90 DAYSApplicable extended period for certain POS debit-card, foreign-initiated, and qualifying new-account EFTsFRONTLINE EMPLOYEES SHOULD NOT PROMISE THE OUTCOMEThe employee's role is to listen, capture accurate information, follow institution procedures, provide required information, and escalate appropriately.Do not promise provisional credit.Do not promise reimbursement.Do not promise final credit.Do not prematurely tell the member the claim will be denied.Let the institution's Regulation E error-resolution process determine the outcome.IMPORTANTSCAM ≠ AUTOMATICALLY UNAUTHORIZED EFTHow the transaction occurred and who initiated the EFT matter.THE FRONTLINE EMPLOYEE DOCUMENTS THE CLAIM — THE INVESTIGATION DETERMINES THE OUTCOME.IDEAL FORBank tellers, credit union tellers, universal bankers, personal bankers, member-service representatives, branch managers, supervisors, new-hire onboarding, Regulation E refresher training, fraud teams, operations teams, and financial-institution trainers.2026 Edition • Version 1.0Created by Jay Get It™ — Practical Banking Training & Compliance ResourcesEducational Use Notice: General educational aid only. This resource does not constitute legal, regulatory, audit, or compliance advice and does not replace institution-specific Regulation E procedures, disclosures, systems, investigation processes, approval authorities, or applicable law and regulatory guidance.