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 / DOCUMENT

WHAT'S INSIDE

Identify the Transaction

• Debit-card transactions
• ATM withdrawals
• ACH transactions
• Electronic account transfers
• Certain P2P/mobile transfers
• Recurring electronic debits

Understand the Fraud Question

The guide helps employees distinguish between:

Consumer-authorized payments
and
EFTs initiated by someone else without actual authority

It 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 GLANCE

10 BUSINESS DAYS
General initial investigation/determination period

45 CALENDAR DAYS
General extended investigation period when applicable requirements are satisfied

20 BUSINESS DAYS
Applicable initial period for certain EFTs involving qualifying new accounts

UP TO 90 DAYS
Applicable extended period for certain POS debit-card, foreign-initiated, and qualifying new-account EFTs

FRONTLINE EMPLOYEES SHOULD NOT PROMISE THE OUTCOME

The 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.

IMPORTANT

SCAM ≠ AUTOMATICALLY UNAUTHORIZED EFT

How the transaction occurred and who initiated the EFT matter.

THE FRONTLINE EMPLOYEE DOCUMENTS THE CLAIM — THE INVESTIGATION DETERMINES THE OUTCOME.

IDEAL FOR

Bank 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 1.0

Created by Jay Get It™ — Practical Banking Training & Compliance Resources

Educational 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.