Your bank must issue provisional credit within ten business days of receiving a valid dispute notice, unless it finishes investigating within that window or your account is new. This ten-day rule for provisional credit comes from Regulation E, which implements the Electronic Fund Transfer Act and governs debit card and electronic transfer disputes. If the bank cannot complete its investigation in ten business days, it has to temporarily restore the disputed amount, plus any lost interest, and keep investigating for up to forty-five calendar days total.1eCFR. 12 CFR 1005.11 Procedures for Resolving Errors
When the Ten-Day Clock Starts
The clock starts the moment the bank receives your error notice, whether you call, use the mobile app, or write in. To count as a valid notice, it needs your name, your account number, and enough detail about the problem — ideally the type, date, and amount of the disputed transfer. The regulation asks for that detail “to the extent possible,” so you do not need the amount down to the cent.1eCFR. 12 CFR 1005.11 Procedures for Resolving Errors
A phone call is enough to start the process. The bank is allowed to ask you to follow up in writing within ten business days of your oral notice, however. If it tells you written confirmation is required and you miss that follow-up, the bank can deny provisional credit while it continues investigating. The ten-day provisional credit clock still runs from your original contact date, not from the date the written confirmation arrives.
Regulation E does not let a bank hold up the investigation while waiting for a police report. Once you provide the basic notice, the obligation begins.
What the Provisional Credit Has to Cover
If the bank uses the extension, the provisional credit must equal the full amount of the alleged error, including any interest you would have earned on an interest-bearing account. Within two business days of issuing the credit, the bank has to notify you of the amount and the date. And you must have full use of the funds for the duration of the investigation, which can run up to forty-five calendar days from the original notice for a standard transaction.1eCFR. 12 CFR 1005.11 Procedures for Resolving Errors
If the bank finishes its review inside the ten business days, no provisional credit is needed. It has to report the results to you within three business days of finishing and correct any confirmed error within one business day.
When the Timeline Runs Longer
Three situations extend the standard schedule under Regulation E:
- New accounts, meaning accounts open thirty days or less, give the bank up to twenty business days instead of ten to complete the investigation or issue provisional credit, and up to ninety days total to finish investigating.2eCFR. 12 CFR 1005.11(c)(3) Extension of Time Periods
- Point-of-sale debit card transactions keep the ten-business-day provisional credit deadline, but the total investigation window stretches from forty-five to ninety days.2eCFR. 12 CFR 1005.11(c)(3) Extension of Time Periods
- Foreign-initiated transfers work the same way: provisional credit within ten business days, up to ninety days to finish the investigation.2eCFR. 12 CFR 1005.11(c)(3) Extension of Time Periods
Only the new-account category actually pushes the provisional credit deadline itself past ten business days. The other two extend only the total time the bank has to reach a final decision.
Prepaid cards are a partial exception. A verified, registered prepaid account gets the same provisional credit timeline described above, though the bank may withhold up to $50 of the credit if it has a reasonable basis to believe an unauthorized transfer occurred. An unverified prepaid account may have no error resolution protections at all, and the issuer must disclose that limitation.3eCFR. 12 CFR 1005.18(e) Prepaid Accounts – Error Resolution
Report Fast to Keep Your Protections
The right to provisional credit depends on filing the dispute in time. Regulation E and the underlying statute set hard reporting deadlines on both unauthorized transfers and other statement errors.
For a lost or stolen card, reporting within two business days of learning about it caps your liability at $50 or the amount of unauthorized transfers, whichever is less. Waiting longer than two business days but reporting within sixty days of receiving your statement raises the cap to $500.4Consumer Financial Protection Bureau. 12 CFR 1005.6 Liability of Consumer for Unauthorized Transfers Reporting more than sixty days after the statement was sent leaves you exposed for the full amount of any unauthorized transfers that happen after that sixty-day window, with no cap.5Office of the Law Revision Counsel. 15 USC 1693g Consumer Liability
That sixty-day statement rule applies to every kind of Regulation E error, not just unauthorized transfers. Miss it and you can lose the right to dispute the transaction at all — which also means losing any right to provisional credit while a dispute is investigated.
When the Investigation Ends
Whether the review takes ten days or forty-five, the bank has to send you its findings within three business days of finishing. A confirmed error must be corrected within one business day, and any provisional credit already in the account becomes permanent.1eCFR. 12 CFR 1005.11 Procedures for Resolving Errors
If the bank decides no error occurred, or that the error was different from what you described, it has to send a written explanation and tell you that you can request copies of the documents it relied on. It can then reverse the provisional credit. When it does, it must give you the date and amount of the reversal and honor checks and preauthorized payments from the account, without charging overdraft fees, for five business days after the reversal notice. That five-day grace period gives you time to deposit funds before other payments bounce.
Credit Cards Do Not Work This Way
Everything above applies to debit cards and other electronic fund transfers. Credit card billing disputes fall under the Fair Credit Billing Act and Regulation Z, which run on a different schedule and do not require provisional credit.
On a credit card, you have sixty days from the date the statement was sent to submit a written dispute to the creditor’s billing inquiries address. The creditor must acknowledge the notice within thirty days and resolve the dispute within two billing cycles, capped at ninety days.6Office of the Law Revision Counsel. 15 USC 1666 Correction of Billing Errors The creditor cannot try to collect the disputed amount or report it as delinquent during that time.
The key difference for anyone waiting on money: Regulation Z says a creditor “may” temporarily correct your account during the investigation, but this is optional.7Consumer Financial Protection Bureau. 12 CFR 1026.13 Billing Error Resolution Many issuers offer temporary credits as a matter of practice, but you cannot compel one the way you can with a debit dispute.
If the Bank Misses the Deadline
A bank that violates the EFTA’s error resolution rules faces civil liability for actual damages plus statutory damages between $100 and $1,000 in an individual lawsuit.8Office of the Law Revision Counsel. 15 USC 1693m Civil Liability
The exposure grows when provisional credit is the specific failure. If a court finds that the bank failed to provisionally recredit the account within ten business days and either did not conduct a good-faith investigation or had no reasonable basis for concluding the account was not in error, you are entitled to treble damages — three times the amount you would otherwise recover.9Office of the Law Revision Counsel. 15 USC 1693f Error Resolution The same treble damages apply when a bank knowingly and willfully concludes no error occurred despite evidence that makes that conclusion unreasonable.
Short of a lawsuit, you can file a complaint with the Consumer Financial Protection Bureau at consumerfinance.gov. The CFPB forwards the complaint to your bank, which generally responds within fifteen days and up to sixty in complex cases.10Consumer Financial Protection Bureau. Learn How the Complaint Process Works For a national bank or federal savings association, the Office of the Comptroller of the Currency also handles consumer complaints through its Customer Assistance Group.11OCC. Consumer Complaints Credit unions fall under the National Credit Union Administration, and state-chartered banks may fall under a state banking regulator.