Electronic Transaction Disputes

• What You Need to Know
• Frequently Asked Questions

What You Need to Know About Reg E and Error Resolution

What types of transactions are covered by Reg E?

Examples of electronic fund transfers impacted by Reg E include:

• Online bill payments
• Visa Debit card transactions (i.e. ATM withdrawals and deposits or payments for purchases and services)
• Transactions originated by check or draft whereby the merchant elects to convert the check or draft to an electronic debit (e.g. "e-checks")
• Preauthorized recurring deposits and payments to or from your checking or savings accounts (i.e. insurance payments, dues and subscriptions and direct deposits of paychecks or government benefit checks).

Transfers not covered by Reg E legislation include:

• Preauthorized transfers between your accounts with RBC Bank.
• Transactions originated by a check or draft where the merchant processes the check or draft in its original format
• Transactions that are originated and processed to or from accounts that are used primarily for business or other non-personal purposes (i.e. charitable or religious organizations)

What disclosures are RBC Bank required to provide?

The disclosures required by Reg E are many and varied, but the most common examples focus on:

• Ways you can access your account for electronic transfers and how we offer you those options
• ATM transaction fees and receipts
• New or changing account terms as they relate to electronic transfers (i.e. limits on transfer frequency or amounts, increased fees, )
• Pre-authorized transfers
• Standard overdraft coverage for electronic transactions

One of the most important areas of concern covered by the regulation is transaction dispute or error resolution. In the event that you believe your account has been subject to an incorrect, unauthorized or unrecognized electronic transfer, there are specific steps that both you and RBC Bank need to make to resolve the potential dispute.

Please review the FAQs regarding error resolution to ensure you know what to do if you need to dispute an electronic transfer.

Have you noticed an error?

Before you dispute a transaction consider the following:

• Did your spouse or significant or complete the transaction?
• Have you reviewed your documentation for the transaction to ensure you are not mistaken about the details?
• Have you contacted the merchant to try to verify the transactions or obtain additional information?
• Have you contacted the merchant to try to resolve and/or correct the transaction?

And remember, transactions completed by someone you allowed to use your card and/or code are not considered unauthorized unless you notified the bank as to the removal of that permission.

Frequently Asked Questions About Error Resolution for Disputed Transactions

What does the term “error” mean and what types of transfers/inquiries are covered?

With respect to Reg E, an "error" is typically defined as an electronic fund transfer transaction that a client identifies as wrong, missing or fraudulent. Examples of electronic transfers covered by this term include:

• An unauthorized electronic fund transfer
• An incorrect electronic fund transfer to or from your account
• The omission of an electronic fund transfer from your account statement
• A processing or accounting mistake RBC Bank made when processing your transfer request
• The receipt of an incorrect amount of money from an ATM
• An electronic fund transfer not properly identified and you do not recognize the transaction
• The consumer's request for documentation and/or for additional information/clarification concerning an electronic fund transfer, including a request the consumer makes to determine whether an error exists.

What is not covered by the term “error”?

• A routine inquiry about your account balance
• A request for information for tax or other recordkeeping purposes
• A request for duplicate copies of documentation

What are the most common reasons for disputing a transaction?

The vast majority of errors reported in electronic funds transfers include the following:

• Fraudulent use of either your card or card number
• Cash not received or partial cash received
• Fees charged
• Duplicate transaction
• Incorrect dollar amount charged
• Unrecognized charges
• Item purchased and returned, but no credit received
• Services not completed or as expected
• Goods or services never received or arrived damaged or not as requested

How do I report an error?

Call ROYAL 5-3® (1-800-769-2553) and be prepared to provide the following information:

• Merchant or business name
• Date of transaction
• Amount of transaction
• Description of error

Is there a time limit or deadline for reporting errors?

Depending on the type of electronic transfer transaction in dispute, there are deadlines for reporting errors.

Lost or Stolen Cards
You must notify us within two business days after you learn of the loss or theft.

Transaction Errors (unauthorized, incorrect amount, merchant errors)
If you identify a transaction error on your statement, such as an unauthorized and/or incorrect amount, we must hear from you no later than 60 days after we send you the FIRST statement on which the problem appears.

What is my liability for unauthorized transfers?

While RBC Bank does its best to protect you from liability related to unauthorized transfers, there are instances where you may be held liable for those types of transactions.

Lost or Stolen Cards
Based on the error notification requirements outlined above, you can lose no more than $50 should someone use your card or code without your permission. If you do NOT tell us within two business days and we could have stopped someone from using your card or code without your permission if you had told us, you could lose as much as $500.

Transaction Errors (unauthorized, incorrect amount, merchant errors)
If you do not notify us within 60 days after the account statement containing the error was sent or made available to you and, if we could have reasonably stopped losses to your account had you notified us of the error in time, you many not recover any money you lose after the 60 day period. We do occasionally make exceptions if extenuating circumstances prevented you from contacting us (long-term travel, hospitalization, etc.).

Does the bank require a written notice or affidavit for a disputed transaction?

Yes. We may require written notice of an error within 10 business days from the time you notify us via telephone. If written notice is required, we will notify you of this requirement at the time you contact us.

Use the ACH Disputes Form - If the transaction being disputed is an electronic transaction, but was not processed using your debit card.

Use the Affidavit of Dispute Form - If the transaction being disputed is an electronic transaction, authorized by you and processed with your debit card but the merchant has made an error.

Use the Affidavit of Unauthorized Dispute Form - If the transaction being disputed is an electronic transaction, not authorized by you but was processed with your debit card.

Where do I send my written notice or affidavit?

Once completed, please send your notice or affidavit to:

Fax: 724-779-2479

Mail:
RBC Bank
PO Box 2461
Cranberry TWP, PA 16066

How long does it take to conduct the investigation?

Once we receive your written notice of error, we will investigate your dispute and try to resolve it within 10 business days.

If we are unable to achieve resolution within 10 business days, we may take an additional 45 to 90 days to further investigate. The investigation timeframes, based on the type of transaction in dispute are as follows:

• PIN and signature based transactions – 45 days
• ACH (Draft) transactions – 45 days
• International transactions – 90 days
• Fraud transactions – 90 days

If additional time is required to investigate, we will provide a provisional credit to your account in the amount of the alleged error within 10 business days of receiving your error.

Is provisional credit considered permanent?

It depends on the results of the investigation.

• If the results of the investigation identify that an error did occur, then you will be sent a letter indicating the results of the investigation and that the provisional credit you were previously provided will then be considered permanent.
• If the results of the investigation identify that an error did not occur, then you will receive a letter outlining the results of the investigation and the date that the provisional credit will be removed from your account.