Dispute

A card dispute is a formal claim by a cardholder that a transaction on their account is incorrect, unauthorised, or represents goods or services not received as agreed. Disputes trigger mandatory investigation rights under federal law, with different frameworks for credit and debit cards.

Credit card dispute (Regulation Z, 12 CFR 1026.13):

A credit card billing-error dispute must be submitted in writing to the issuer's designated dispute address within 60 days of the first statement showing the error. The dispute letter should identify the amount in question and explain why it is a billing error. The issuer must: - Acknowledge the dispute within 30 days - Investigate and resolve within two complete billing cycles (maximum 90 days) - Not collect the disputed amount, charge interest on it, or report it as delinquent while investigating - Provide a written explanation if the dispute is denied

Debit card dispute (Regulation E, 12 CFR 1005.11):

A debit EFT error dispute must be reported to the bank within 60 days of the first statement showing the disputed transfer to avoid unlimited liability (see Reg E 1005.6). The bank must: - Investigate within 10 business days for most transactions (45 days maximum) - Issue provisional credit within 10 business days if it cannot complete the investigation in that time - Notify the consumer of the results within 3 business days of completing the investigation

Key difference: Credit disputes cover billing errors including merchant disputes (goods not received, subscription not cancelled). Debit disputes cover only EFT errors (transfer incorrectly executed). A merchant-quality dispute on a debit card may not qualify as a Reg E error.

Second key difference, and the one most consumers get wrong: the form the notice has to take. Reg Z 1026.13(b) defines a billing error notice as "a written notice from a consumer" received at the address the issuer discloses for billing inquiries. A phone call is not a billing error notice and does not start the 1026.13 clock or trigger the protections in 1026.13(d), so a cardholder who only ever telephones has no statutory claim to fall back on if the issuer declines. An electronic submission counts as written, but only where the issuer has stipulated in its billing rights statement that it accepts electronic billing error notices and stated the means of doing so (Official Interpretation to 1026.13, paragraph 13(b)). Reg E is the opposite: 1005.11(b)(1) accepts "any oral or written notice of error", so a phone call to your bank about a debit transaction is legally sufficient on its own. The bank may require written confirmation within 10 business days, but only if it tells you so and gives you the address at the time of the call (1005.11(b)(2)).

Practical steps: telephone first to get the card frozen and the investigation opened, then put it in writing regardless of card type. Send the credit card notice to the billing inquiries address printed on your statement, not the payment address. Keep copies of all correspondence, note the date sent, and include documentation (cancellation confirmation, order records, communication with the merchant).