[TheBank]

If an item has memo posted to a consumer’s account, or is pending, does that constitute a transaction covered by the Reg E dispute rules? The definition of EFT requires the item be a debit or credit to an account. Would a memo post / pending item the account holder sees on our mobile app or online banking be subject to investigation if reported as fraudulent while in memo post? OR is it permissible to not investigate/accept a reg e dispute on an item until it actually posts?

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[Brent V]

It has to post to the account. Once posted at that point the customer can submit a dispute. You could communicate to the customer information on the pended transaction but for Reg E it has to be posted.

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