Regulatory Service Level Agreements
- Devan Robertson
- Kristafanie Somers
- Jacob Harris
- Geordie Connell
Overview
QFD is pre-configured with Service Level Agreements (SLAs) to ensure that regulatory requirements are satisfied. When applicable, regulatory SLA milestones are visible in Claim Details.
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.
SLA | Milestone | Property | Action | Note |
|---|---|---|---|---|
Reg E 10 Protection | 10 Business Days | RegE10 | Grant provisional credit and send the provisional credit letter |
|
Reg E 20 Protection | 20 Business Days | RegE20 | Grant provisional credit and send the provisional credit letter | If the disputed transaction occurred within 30 days of the account open date, this milestone is 20 Business Days. See Reg E 1005.11(c)(3)(i). |
Reg E 90 Protection | 90 Days | RegEDeadline | Execute write-off and send the resolution letter |
|
US ATM and ACH Disputes
The following configuration applies to all disputed US ATM transactions.
SLA | Milestone | Property | Action |
|---|---|---|---|
Reg E 10 Protection | 10 Business Days | RegEApproachingDate | Grant provisional credit and send provisional credit letter |
Reg E 45 Protection | 45 Days | RegEDeadline | Execute write-off and send the resolution letter |
Unknown Country Code
If Country Code is not provided by the system of record for ATM transactions, the SLA will default to Reg E 45 for all ATM transactions.
ACH Claims
Provisional credit is only issued on business day 10 for ACH claims when a written statement has been provided by the claimant. For more information about required documents, see Customer Documentation.
Mixed ATM and POS Transaction Claims
When a claim contains a mix of ATM and POS transactions the regulatory deadline will be set to 45 days for all disputed transactions. Regulatory deadlines are set at the claim level and this will insure all regulatory obligations are met. It also provides a consistent message to the customer regarding the timeline on when the claim will be resolved.
Regulation Z
Credit Card Disputes
The following configuration applies to all disputed credit card transactions.
SLA | Milestone | Property | Action |
|---|---|---|---|
Reg Z 30 Protection | 30 Days | RegZ30 | Send the acknowledgement letter |
Reg Z 90 Protection | 2 Complete Statement Cycles | RegZ90 | Execute write-off and send the resolution letter |
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.
SLA | Milestone | Property | Action |
|---|---|---|---|
Reg Z PC Protection | Reg Z Withholding Date | RegZPCThreshold | Grant provisional credit and send the provisional credit letter |
The Reg Z Withholding date is set based on the following rules:
If Next Autopayment Date and Statement Cycle Date are known, Reg Z Withholding date is set to the earlier of the 2 days
Autopayment Date is reduced by 1 day to ensure credit is issued before the payment is processed
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.
SLA | Milestone | Action |
|---|---|---|
FCRA Protection | 30 Days | Execute write-off and send the resolution letter |