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Customer Support and Complaints
- 11 Jul 2024
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Customer Support and Complaints
- Updated on 11 Jul 2024
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Customer Support, Disputes, and Complaints
Because you own the customer relationship, you are responsible as a first line to any interactions with your customer. This includes fielding requests on how your app works, technical issues, and customer complaints.
- Your customer support policy or guide should describe your general process and tools for responding to your customers.
- Your Sponsor Bank will be especially interested in how you interact with consumers (if applicable) as there are general guidelines and rules pertaining to consumer complaints and transaction disputes. This includes a responsibility of your Company to log customer complaints that you receive directly or through regulators such as the Federal Reserve or Consumer Financial Protection Bureau. Managing these complaints promptly and addressing any major themes that occur can protect you from reputation and legal risks.
- It also includes ensuring that you follow the response timelines and have the ability to provide provisional credits to consumers according to Regulation E, which addresses consumer disputes on electronic transactions such as debit card and ACH transactions. In addition, there are cases where fraudsters may file disputes and having trained experts manage the responses can help mitigate fraud losses or excessive issuance of provisional credit by the Company.
Reg E Disputes
Customers can dispute transactions for many reasons ranging from not recognizing the transaction to fraudulent transactions by an unauthorized user. The most common reasons for disputes are as follows:
- Amount discrepancy
- Duplicate/Unauthorized transaction
- Victim of fraud, card theft, or identity theft
- Returned merchandise (generally not covered by Reg E)
- Product/Service not as described or not received (generally not covered by Reg E)
Reg E Disputes
Reg E outlines rules for electronic funds transfers between consumers and financial institutions. This covers transfers made through ATMs, point-of-sale transactions, and ACH systems.
It was created by the U.S. Federal Reserve to enforce the Electronic Funds Transfers Act, which was passed in 1978 by the U.S. Congress to safeguard consumers participating in financial transactions like these.
Reg E disputes have specific timelines and steps that must be followed. Only certain types of disputes are considered Reg E disputes and the regulation only covers consumer disputes.
Reg E vs. Standard Complaints
At first glance, Reg E disputes can seem very similar to standard complaints. They differ in some fundamental ways in terms of scope and how they are resolved however:
Reg E dispute requirements
Under Reg E, consumers are entitled to receive provisional credit and financial institutions are not allowed to demand excessive requirements from them. The customer is only required to provide the following information:
- Merchant name
- Transaction Amount
- Transaction Date
- Error Description
Initial customer contact (ICC) is the date the customer has reported the error, which triggers the dispute timeframes. Below are the guidelines for a date to be considered an ICC:
- Transaction Identifying Information has been provided
- Mention of Dispute Reason
- At least one (1) settled transaction
Exemptions from Reg E
Regulation E protects consumer electronic fund transfers, but not all errors fall under its scope. Please note that these are general examples, and specific details can vary. Transactions and errors outside the scope of Reg E include:
- Returned Merchandise
- Merchandise/Service not Received
- Merchandise not as described
- Merchandise damaged/defective
- Canceled Merchandise/Service (one-time transaction)
- Errors Beyond the 60-day Timeframe
- Business/Commercial Transactions
CFPB Complaints Database
The CFPB Complaints Database is a publicly available database where companies can view and sort through complaints on financial companies and fintechs. This can be a useful way to see the types of complaints that may be emerging in your product type or industry. It also gives you a sense of what the CFPB may be tracking and what your Sponsor Bank partner will be focused on. Note that consumers can also directly make complaints about your Company via the CFPB so it is important that as part of complaint tracking, there is ongoing search of CFPB to check if there are any complaints about your business.
Customer Communication
These templates are provided for your reference and convenience. It is the responsibility of the FinTech to communicate case updates and outcomes to customers. Always check the policies and procedures set by your Partner Bank, as Synctera only offers back-office support for disputes, and the FinTech, under the supervision of its Partner Bank, is responsible for front-line customer support and communication.
Best Practices
- Except for fraud disputes, the customer should attempt to contact the merchant directly to resolve the issue. If the issue cannot be resolved, a dispute can be initiated.
- The disputed transaction must be posted to the customer account. A pending transaction cannot be disputed.
- Request supporting documentation, such as receipts or email communication with the merchant and timelines.
- When a card is reported lost, stolen, or compromised, immediately freeze the card to prevent unauthorized transactions.
| Notification | Description/Timing | Example |
|---|---|---|
| Acknowledgment | Promptly acknowledge the notice, provide details about any provisional credit, and explain the investigation process. | We are sorry to hear that your account contains a potential error. This message is to acknowledge the receipt of your dispute received [Date of Dispute Notice]. We will investigate your claim, and will provide a resolution once this matter has been fully investigated. We appreciate your patience and cooperation in this matter. |
| Provisional Credit | Provisional credit must be provided within 10 business days for established accounts and within 20 business days for new accounts. Notify about the provisional credit within 2 business days of issuance and that it is subject to reversal based on the outcome of the investigation. | While we continue to investigate your dispute, we have credited your account with the disputed amount of [disputed amount]. This is temporary credit that is effective as of [date of credit]. We will notify you of the outcome of our investigation by [date] at which time this provisional credit will either become permanent or be reversed depending on the outcome of the investigation. |
| Request Additional Info | When applicable, request more information or documentation to assist in the investigation. Provide clear instructions on what is needed and how to submit it. | We have begun investigating the transaction on your account dated [Transaction Date]; however, we need additional documentation or information, as noted below: [Information Needed to be Listed in Dispute Case]. Your prompt response will help us resolve this matter as quickly as possible. Failure to provide the requested information may impact the outcome of your claim. |
| Canceled Dispute | Promptly acknowledge the request, confirm that the investigation will end, and outline any actions taken or needed as a result. | We have received your request to cancel your claim regarding the transaction on your account dated [Transaction Date]. As requested, we have stopped our investigation, and we reversed the provisional credit of [$X.XX] on [Date]. |
| Resolution: Error Found - Provisional Credit Final | Notify the customer of the results within 3 business days. Provide details of the correction and confirm the final credit. | We have completed our investigation of the disputed transaction on your account and have determined that your claim is valid. The disputed amount of [$X.XX] has been permanently credited to your account. |
| Resolution: Error Found - No Provisional Credit, Final Credit Issued | Notify the customer of the results within 3 business days. Provide details of the correction and confirm the final credit. | We have completed our investigation regarding the claim on your account dated [Transaction Date] and have determined that your claim is valid. The investigation was completed before a provisional credit was due, therefore a final credit of the disputed amount of [$X.XX] has been permanently credited to your account. |
| Resolution: Error found - Merchant Refund, Provisional Credit Revoked | Notify the customer of the results within 3 business days. Provide details of the merchant refund, and confirm the date and amount of the provisional credit reversal. | We have completed our investigation regarding the claim on your account dated [Transaction Date]. Upon further review, we found that the merchant issued a refund for (amount) on [Date]. As a result of the merchant's refund, the provisional credit of [$X.XX] will be debited from your account on [Debit Date]. |
| Resolution: Error Found - Merchant Refund, no Provisional Credit | Notify the customer of the results within 3 business days. Provide details of the merchant refund, and confirm that no provisional credit was issued. | We have completed our investigation regarding the claim on your account dated [Transaction Date]. Upon further review, we found that the merchant issued a refund for [$X.XX] on [Date]. As the refund was issued by the merchant, no provisional credit was provided during the investigation period. |
| Resolution: No Error - Provisional Credit Revoked | Notify the consumer of the results within 3 business days. Provide an explanation, disclose their right to request additional info, and promptly provide copies of the documents upon request. Include the date and amount of the provisional credit reversal, along with the fees for overdraft disclosure, 12 CFR 1005.11(d)(2). | We have completed our investigation regarding the claim on your account and have determined that no error occurred. The provisional credit of [$X.XX] will be debited from your account on [Debit Date]. We will honor checks, drafts, and similar instruments payable to third parties and preauthorized transfers from your account without charge to you as a result of an overdraft for five business days after this notification. You have the right to request additional information and documentation relied upon in making these determinations. |
| Resolution: No Error - No Provisional Credit | Notify the consumer of the results within 3 business days. Provide an explanation, disclose their right to request additional info, and promptly provide copies of the documents upon request and confirm that no funds will be credited to their account. | We have completed our investigation regarding the claim on your account dated [Transaction Date] and determined that no error occurred. As a result, a final credit was not issued to your account. You have the right to request additional information and documentation relied upon in making these determinations. |
Dispute Intake Questions
Asking targeted questions is crucial to uncovering factual information from customers. This helps remove ambiguity, obtain more details, and encourage customers to provide comprehensive answers. Documenting all relevant information in the case is important to fully understand the customer's dispute. Here are some questions you can use based on the type of dispute.
Unauthorized Transaction
The customer was not involved or did not know of the transaction.
- Did the customer make the transaction?
- When and where was the last time the customer made an authorized transaction?
- Does the customer have their card with them?
- Have you given anyone else permission to use the card?
- Have you checked with them to see if they performed this transaction?
- Is the card lost, stolen, or never received?
- When was the card lost or stolen, if applicable?
- Can the customer provide any documentation? It's not required for unauthorized charges, but it can help the investigation.
Duplicate Charge
The customer only made one transaction and was charged more than once.
- Did the customer attempt to contact the merchant?
- How many times was the customer account charged for the same transaction?
- Were the charges on the same day?
- Does the customer have a receipt for the transaction?
Incorrect Amount
The customer authorized a different amount than the settled amount.
- Did the customer attempt to contact the merchant?
- What was the amount the customer was charged?
- What was the amount the customer was expected to be charged?
- Does the customer have an invoice/receipt or other proof?
Paid By Other Means
The customer used a different form of payment for this specific transaction.
- Did the customer attempt to contact the merchant?
- What is the other method of payment?
- When was the second payment made?
- Does the customer have an invoice/receipt or other proof?
Refund Not Posted/Processed
The merchant promised the customer a credit not reflected on the account.
- Did the customer attempt to contact the merchant?
- Why is the merchant processing a refund for this transaction?
- What date did the merchant process the refund?
- How much is the amount the merchant is refunding?
- What time frame did the merchant provide to receive the refund?
- What is the merchandise that was returned?
- Does the customer have documentation or other proof?
Not as described, not delivered, or defective merchandise
The merchant provided incorrect, faulty, counterfeit items or failed to fulfill services.
- Did the customer attempt to contact the merchant?
- When did the customer purchase the product/service?
- When was the customer supposed to receive the product/service?
- Does the customer have a receipt or confirmation?
- Does the customer have documentation, tracking #, or other proof?
Non-receipt of Cash
The customer claims the ATM did not disburse funds.
- Did the customer attempt to contact the merchant?
- How much did the customer attempt to withdraw?
- Did the customer get a receipt?
- How much was dispensed?
- Was there an error?
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