Reg E and Mastercard

Regulation E came back into the news in a big way when the CFPB levied a $3.5 million civil money penalty and $12 million in restitution against an institution for incorrectly processing dispute claims. In December 2021 the CFPB issued several FAQs relating to the proper handling of claims with a particular focus on person to person (P2P) payments. The FAQs redefined the financial institution’s responsibility when a consumer’s third-party login credentials are compromised. A proper understanding of which claims we must pay and which we can deny is critical to managing our risk. Compliance with Regulation E places financial risk on an institution when paying customer claims, but these risks can be significantly amplified when combined with the compliance risks and reputation risks of getting the claims process wrong. Don’t let your institution fall into the trap of shortsightedly denying claims without adequate investigation or misapplying conflicting Mastercard and Regulation E requirements.

Key takeaways:

• Compare and contrast Reg E requirements and Mastercard Rules
• Understand Reg E Liability vs. Mastercard Zero Liability
• Apply Mastercard rules to business debit cards
• Understand the use of Mastercard’s chargeback process in a Reg E investigation
• Learn from Reg E enforcement actions and penalties
• Identify investigation strategies to aid in loss mitigation