- What qualifies as a Regulation Z billing error.
- The cardholder notification requirements for reporting an error.
- The investigation timeline, your requirements during that period, and what counts as a reasonable investigation.
- How to resolve a dispute, whether an error occurred or not.
- What webhooks are available for Regulation Z billing error disputes.
Marqeta offers investigation and resolution services for Regulation Z billing error disputes.
The party responsible for these services is determined by the terms of your contract.
Please refer to your agreement to confirm which party is responsible.
What qualifies as a Regulation Z billing error?
The following problems on a cardholder’s credit account are covered by Regulation Z billing error protections:- Unauthorized transactions: Charges the cardholder didn’t authorize.
- Incorrect amounts: Wrong amounts charged or credited to the account.
- Computational errors: Mathematical or accounting mistakes.
- Payment or credit omissions: Payments or credits issued to the cardholder that are not properly reflected on the periodic statement.
- Misidentified transactions: Transactions described incorrectly on statements.
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Non-delivery issues: Extensions of credit for properties or services that were:
- Charged for, but not accepted by the cardholder or their designee.
- Not delivered as agreed, or delivered late.
- Delivered as the wrong item or service from what was agreed upon.
- Delivered with the wrong quantity, or to the wrong location.
- Request for clarifications: Charges for which the cardholder requests additional clarification.
- Statement delivery failures: Failure to deliver a periodic statement to the cardholder’s last known address, where that address was received in writing at least 20 calendar days before the end of the billing cycle.
What does not qualify as a Regulation Z billing error
The following are not covered by Regulation Z billing error protections:- Quality disputes for goods or services.
- Routine balance inquiries.
- Requests for tax or recordkeeping information.
- Requests for duplicate documents.
Cardholder notification requirements
Regulation Z’s error-resolution procedures are triggered by a billing error notice, which is a written notice from the cardholder, received at the location indicated as the designated channel (physical mailing address or electronic/digital channel) for receiving error notices in the required disclosures and periodic statements. The cardholder must submit the notice within 60 days after the first periodic statement that reflects the alleged error is transmitted. The notice must include the following:- The cardholder’s name.
- The account number.
- An indication of why the cardholder believes an error exists, including (if possible) the type, date, and amount of the error.
Investigation timeline
After a billing error notice is received, the following milestones apply.Acknowledgment within 30 days
Written acknowledgment must be provided to the cardholder within 30 days of receiving the error notice, unless the investigation is completed within that period.Resolution within two billing cycles
The investigation must be completed and the dispute must be resolved within two complete billing cycles—and no more than 90 days—after receiving the error notice. For the specific actions required based on the outcome, see Resolution requirements.Reasonable investigation standard
A reasonable investigation must be conducted before determining whether a billing error occurred or that a different billing error occurred from that asserted. A creditor must consider the facts that it has knowledge of to confirm a billing error. Investigation requirements vary based on the type of error.Restrictions during the investigation
While the investigation is open, all of the following apply to the disputed amount and any related finance or other charges:- The cardholder is not required to pay, and no collection attempts can be made on any portion of the disputed amount, including finance or other charges.
- The account may not be reported as delinquent, and no adverse action may be taken, unless other undisputed portions remain unpaid.
- The debt may not be accelerated, and the account may not be restricted or closed, solely because of the billing error assertion.
Cardholder cooperation
A cardholder’s cooperation may be requested during an investigation, but a claim may not be denied solely because the cardholder didn’t comply with a particular request, such as providing an affidavit or filing a police report. However, a lack of information may result in a finding that no error occurred.Examples of billing error investigations
The following are examples of billing errors and their investigation standards.Investigating non-delivery claims
For non-delivery claims, it must be determined whether the property or services were actually delivered, mailed, or sent as agreed.Investigating unauthorized transactions
For unauthorized transactions, an investigation may include the following:- Reviewing purchase types and amounts against the cardholder’s previous patterns.
- Comparing delivery locations to the cardholder’s residence or business.
- Examining purchase locations relative to the cardholder’s normal shopping areas.
- Comparing signatures on credit slips.
- Requesting documentation or a written statement from the cardholder, but not an affidavit made under penalty of perjury.
- Requesting a police report, if the cardholder filed one.
Resolution requirements
The following tables summarize the actions that must be performed depending on whether the investigation finds that an error has occurred.For details on how these outcomes are represented on Marqeta’s credit platform, see Dispute statuses.
Error occurred: case won
If the investigation confirms the billing error, the following actions are performed.No error occurred: case lost
If the investigation finds no billing error, the following actions are performed.Webhooks
In addition to the dispute webhooks documented for Marqeta’s credit platform, the credit platform sends the following webhooks for Regulation Z billing error disputes:
For more information on subscribing to webhook notifications, see About Webhooks.