When a consumer reports an unauthorized or erroneous electronic fund transfer, Regulation E starts a clock. A bank generally has 10 business days to investigate a notice of error, or it must provide provisional credit and take up to 45 calendar days to complete the investigation. For certain new accounts, point-of-sale, and foreign-initiated transactions, the investigation window extends to 90 days. Missing these deadlines is itself a violation, independent of whether the underlying transaction was actually unauthorized.
Key Takeaways:
- The consumer has 60 days from the statement date to report an error to preserve their Reg E protections
- The bank has 10 business days to investigate, or must give provisional credit and take up to 45 calendar days
- New accounts (first 30 days), POS debit card, and foreign-initiated transfers extend the investigation to 90 days
- If provisional credit is given, the bank must do so within the 10-business-day window
- After completing the investigation, the bank has specific deadlines to report results and, if no error is found, to notify the consumer before reversing credit
These rules live in 12 CFR § 1005.11, the error resolution section of Regulation E, which implements the Electronic Fund Transfer Act.
What Counts as an Error Under Regulation E
Regulation E error resolution applies to a defined set of errors involving electronic fund transfers, including:
- An unauthorized EFT
- An incorrect EFT to or from the consumer's account
- An omission of an EFT from a periodic statement
- A computational or bookkeeping error by the institution
- The consumer's receipt of an incorrect amount of money from an ATM or terminal
- An EFT not identified correctly on a statement or terminal receipt
- A consumer request for documentation or clarification, including additional information about a transfer
Reg E governs electronic transfers from consumer accounts, debit card transactions, ATM withdrawals, ACH transfers, and similar EFTs. It generally does not cover business accounts, checks, or wire transfers between financial institutions. For the broader scope, see our Regulation E requirements for banks.
The 60-Day Consumer Notice Window
The consumer's clock comes first. To preserve full Reg E protection, the consumer must notify the bank of an error within 60 days after the institution sends the periodic statement showing the error. The notice can be oral or written.
If the consumer notifies the bank orally, the bank may require written confirmation within 10 business days. Critically, the bank cannot delay starting its investigation while waiting for that written confirmation, and it cannot deny a claim solely because the consumer did not send written confirmation, although it may withhold provisional credit in that situation.
When the consumer reports outside the 60-day window, the institution's obligations are reduced, but it must still act reasonably and may have obligations under its account agreement and other law.
The Core Investigation Timeframes
Once the bank receives a valid notice of error, the central timeframes apply.
The 10-Business-Day Rule
The institution must investigate and determine whether an error occurred within 10 business days of receiving the notice. If it resolves the matter in the consumer's favor within those 10 days, it corrects the error, including crediting any disputed amount and related fees, and reports the result.
Provisional Credit and the 45-Day Extension
If the bank cannot complete its investigation within 10 business days, it may take up to 45 calendar days total, but only if it:
- Provisionally credits the consumer's account for the disputed amount, including applicable fees, within the 10-business-day window
- Notifies the consumer of the provisional credit amount and date within two business days of providing it
- Gives the consumer full use of the funds during the investigation
If the bank chooses not to provide provisional credit, it loses the 45-day extension and must complete its investigation within the 10-business-day period.
The 90-Day Extension for Certain Transactions
The investigation window extends from 45 to 90 calendar days for:
- Transactions on new accounts (during the first 30 days after the first deposit)
- Point-of-sale debit card transactions
- Foreign-initiated transfers
For new accounts, the bank also has up to 20 business days (instead of 10) to provisionally credit the account.
| Scenario | Investigate within | If extended (with provisional credit) |
|---|---|---|
| Standard EFT | 10 business days | Up to 45 calendar days |
| New account (first 30 days) | 20 business days | Up to 90 calendar days |
| POS debit card | 10 business days | Up to 90 calendar days |
| Foreign-initiated | 10 business days | Up to 90 calendar days |
Reporting Results and Reversing Provisional Credit
The investigation is only half the obligation. The bank must also report and, where applicable, unwind provisional credit correctly.
If the bank finds an error occurred: It must correct the error within one business day of determining it occurred, including crediting the disputed amount and any related fees, and then report the result to the consumer within three business days of completing the investigation.
If the bank finds no error, or a different error: It must send a written explanation of its findings within three business days of completing the investigation and note the consumer's right to request the documents the institution relied on. If provisional credit was given and the bank determines no error occurred, it must notify the consumer of the date and amount of the debit reversal and honor items or transfers for five business days after the notice to avoid imposing fees or charges from the reversal.
This last step is a frequent source of violations. Reversing provisional credit without the required notice, or without the five-business-day grace period, is a Reg E error in itself.
Common Regulation E Timing Violations
Examiners reviewing deposit compliance look closely at error resolution timing. Recurring problems include:
- Blowing the 10-day deadline without providing provisional credit, then taking the full 45 days anyway
- Provisional credit given late, after the 10-business-day window
- Reversing provisional credit without the required notice or grace period
- Treating the 60-day consumer window as a hard denial trigger when the bank still has obligations
- Misclassifying transactions and applying the 45-day rule to POS or foreign transfers that qualify for, but also require correct handling under, the 90-day rule
- Requiring written confirmation as a precondition to starting the investigation
Because these are timing rules, they are easy to monitor and easy for an examiner to test against your dispute logs. Reg E timing failures often appear alongside Regulation CC funds availability issues in deposit compliance exams, since both turn on deadlines tied to the same accounts.
Reg E error resolution is a deadline-driven workflow where a missed date is the violation. See how Canarie tracks each dispute against its Reg E clock with evidence at every step →
Frequently Asked Questions
How long does a bank have to resolve a Regulation E dispute?
A bank must investigate within 10 business days of receiving notice of an error. If it cannot finish in that time, it may take up to 45 calendar days, but only if it provides provisional credit within the 10-business-day window. For new account, point-of-sale debit, and foreign-initiated transactions, the investigation window extends to 90 days.
What is provisional credit under Reg E?
Provisional credit is a temporary credit the bank places in the consumer's account for the disputed amount when it cannot complete its investigation within 10 business days. The bank must provide it within the 10-business-day window, notify the consumer within two business days, and give full use of the funds during the investigation.
When does the 90-day Reg E timeframe apply?
The 90-day investigation window applies to transactions on new accounts during the first 30 days after the first deposit, point-of-sale debit card transactions, and foreign-initiated transfers. For all other EFTs, the extended window is 45 days.
How long does a consumer have to report a Reg E error?
A consumer must notify the institution within 60 days after it sends the periodic statement showing the error to preserve full Regulation E protections. The notice can be oral, though the bank may require written confirmation within 10 business days.
Can a bank reverse provisional credit if it finds no error?
Yes, but it must follow specific steps. If the bank determines no error occurred, it must notify the consumer of the date and amount of the debit reversal and honor transactions for five business days after the notice without imposing fees or charges resulting from the reversal.
Make the Reg E Clock Visible
Every Regulation E dispute is a series of deadlines: 10 business days, 45 or 90 calendar days, two business days for the provisional credit notice, three business days to report results. When those clocks live in someone's memory or a manual spreadsheet, deadlines slip and the timing miss becomes the violation.
Canarie tracks each dispute against its Reg E deadlines, prompts the required actions, and captures the evidence of timely investigation, notice, and resolution that examiners ask for.