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Consumer Lost

Updated April 2026 · CFPB Complaint Pattern

Case Study: Subscription Kept Charging After Cancellation on Debit Card, Dispute Filed Late

A common CFPB complaint pattern: consumer cancels a subscription, merchant continues billing the debit card, consumer only notices months later and files a dispute past the Reg E protection window. Credit card would have succeeded via Reg Z.

Complaint Summary

Consumer subscribed to a streaming service at $14.99/month, paid via debit card linked to checking account. Consumer cancelled the subscription in writing via the service's cancellation portal and received a confirmation email. Despite cancellation, the merchant continued billing $14.99 per month for four consecutive months (total: $59.96 in unauthorized post-cancellation charges).

Consumer noticed the charges while reviewing bank statements approximately 95 days after the first post-cancellation charge. Consumer contacted the bank to dispute all four charges. Bank investigated and denied the dispute for the first two charges (charges 1 and 2, occurring on days 0 and 30 of the post-cancellation billing) because those occurred more than 60 days before the statement date reviewed by the consumer.

Bank issued provisional credit for charges 3 and 4 (occurring on days 60 and 90) while investigating. Investigation completed 45 days later; the bank recovered charges 3 and 4 from the merchant but confirmed charges 1 and 2 were outside the Reg E 60-day window. Consumer lost $29.98.

What happened legally

Regulation E 12 CFR 1005.6(b)(3): For unauthorized EFT transfers appearing on a periodic statement, the consumer must report the error within 60 days of the statement date to maintain protection. Charges appearing on statements older than 60 days lose Reg E protection; the bank is not required to credit them.

The 60-day cliff in practice: The consumer received monthly statements. Each statement showed one unauthorized charge. The consumer only noticed all four charges together 95 days after the first charge appeared. By that point, the first charge had been on two statements; the 60-day window for the first statement had closed.

Was this an EFT error? The bank also had grounds to argue the transfers were not EFT errors at all under Reg E 12 CFR 1005.11, because the merchant still had the consumer's stored payment authorization in their system. The transfers were technically executed correctly; the dispute was about the merchant's breach of the cancellation agreement, not a failure in the EFT itself.

How a credit card would have handled this

Under Regulation Z 12 CFR 1026.13(a)(3), a "billing error" includes goods or services not accepted by the cardholder or not delivered as agreed. A subscription that continued charging after cancellation is a textbook billing error: the service was cancelled (not accepted as agreed for future periods); each subsequent charge is a billing error.

The 60-day window under Reg Z runs from each individual billing statement. Even though the consumer noticed the charges 95 days after the first charge, each charge appears on a different monthly statement. The consumer could dispute each charge within 60 days of the statement showing that charge. Even if the first charge was outside the window (95 days), charges 2, 3, and 4 would each have their own 60-day clock running from their respective statement dates.

Credit outcome

Full recovery of at least charges 2, 3, and 4 ($44.97) likely; charge 1 potentially recoverable if within 60 days of that statement. No dollar loss on a credit card for this fact pattern.

What the consumer could have done differently

  • 1Review bank statements monthly. The 60-day Reg E window starts on the statement date. Monthly review ensures each unauthorized charge is caught within its own window.
  • 2Cancel subscriptions via both the merchant AND your bank. Under Reg E 12 CFR 1005.10(c), you can instruct your bank to stop a preauthorized EFT at least 3 business days before the next scheduled transfer. Even if the merchant ignores your cancellation, the bank can block the next charge.
  • 3Use a credit card for subscriptions. For subscription billing, Reg Z's merchant-dispute right (12 CFR 1026.13(a)(3)) is the correct tool. The dispute window runs from each statement showing a billing error.
  • 4Keep the cancellation confirmation. Documentary evidence of cancellation (email, screenshot) is essential for both Reg Z and Reg E disputes. The consumer in this case had the confirmation email, which helped recover charges 3 and 4.
  • 5File CFPB complaint if bank denies. The CFPB forwards complaints to the bank and tracks responses. This escalation sometimes yields goodwill credits for charges technically outside the statutory window.

Sources & regulatory basis

Subscriptions guide →Reg E glossary entry →Check your dispute window →