Regulatory Service Level Agreements

Overview

SLAs are calculated based on the Contact Date associated with the claim and according to the criteria shown below.

Regulation E

ATM/Debit Card Point of Sale and non-US ATM Disputes

The following configuration applies to all point of sale and non-US ATM transactions on ATM and debit cards.

US ATM and ACH Disputes

The following configuration applies to all disputed US ATM transactions.

Regulation Z

Credit Card Disputes

The following configuration applies to all disputed credit card transactions.

Reg Z 90 Calculation

The Statement Cycle Date property is used to calculate the Reg Z 90 deadline. The Reg Z 90 day is equal to the 2nd cycle date following the contact date. For example, if a claim is filed on October 1st and the statement cycle date is October 7th, the Reg Z 90 date is set to December 7th. The date will never exceed 90 days from the contact date. If the statement cycle date is not available, or the calculation results to less than 60 days, the Reg Z 90 date is set to 60 days from the contact date. As an alternative, if cycle dates are consistent by BIN, a special Billing Cycle configuration is available.  This evaluation occurs when the claim is submitted and post-enrichment.

Regulation Z Withholding Protection

This feature is optional and must be explicitly enabled via Client Settings.  The purpose of this regulatory feature is to provide coverage for § 1026.13(d), which requires issuers to prevent any attempts to collect on any disputed portion of a bill.  This is primarily applicable to consumers that are enrolled in automatic bill payment where their credit card bill is paid by automatic deduction on a specific date.  However, it can also extend to disputed transactions being included on the consumers statement if proper disclosures are not present.  When this feature is enabled, and the consumer is enrolled in autopayment or enrollment is unknown, a Reg Z Withholding date is set on the claim.  If the disputed transactions are not placed in dispute status or issued credit by the date set, the system will automatically issue provisional credit.

The Reg Z Withholding date is set based on the following rules:

1. If Next Autopayment Date and Statement Cycle Date are known, Reg Z Withholding date is set to the earlier of the 2 days

2. Autopayment Date is reduced by 1 day to ensure credit is issued before the payment is processed

3. If Contact Date + 3 business days is greater than the date set, Reg Z Withholding date is set to Contact Date + 3 business days (the regulation provides a 3-day grace period for issuers)

FCRA

Credit Card Disputes

The following configuration applies to all disputed credit card transaction where the Credit Report Error Dispute Override is enabled and activated by a user.