TD Provisional Credit: How It Works, Timing, and Denials

TD Bank provisional credit is a temporary deposit the bank must place in your account when it can’t finish investigating a disputed debit card charge or electronic fund transfer within 10 business days. Federal rules under the Electronic Fund Transfer Act and Regulation E require it, the money is yours to use while the investigation continues, and it becomes permanent if the dispute is resolved in your favor. If the bank sides with the merchant, the credit gets reversed.

When TD Bank Has to Issue Provisional Credit

The trigger is time. Once you report an error or unauthorized transaction, TD Bank has 10 business days to investigate and reach a decision. If it can wrap up in that window, you get the outcome and no provisional credit is needed. If it can’t, the bank must credit your account for the full disputed amount, including any applicable interest, and continue investigating.¹

New accounts get a longer runway. If your account is within 30 days of its first deposit, the bank has 20 business days instead of 10 before it must post provisional credit.²

The One Way to Lose Provisional Credit Before It’s Issued

There’s a single scenario where TD Bank can skip provisional credit entirely. If you reported the dispute by phone, the bank asked you to send written confirmation, and you don’t provide it within 10 business days, the bank is off the hook. It has to tell you during the initial call that the written follow-up is required and where to send it. If it did, and you didn’t send the letter, no provisional credit is owed.¹ Treat that follow-up letter as non-optional.

Using the Money While the Investigation Continues

Once the provisional credit posts, you can spend it. The bank can’t restrict access to those funds or place a hold on them. Think of it as the cost the bank pays for needing more time.

The catch is that the money is conditional. If the investigation ends against you, TD Bank takes it back. So while nothing legally stops you from spending it, keep enough of a cushion in the account that a reversal won’t push you into overdraft.

How Long the Investigation Can Last

The outer deadline for TD Bank to finish investigating depends on the kind of transaction you’re disputing.

45 calendar days for most electronic fund transfers, including ATM withdrawals and direct transfers.³
90 calendar days for three categories: point-of-sale debit card transactions, transfers not initiated within the United States, and transactions on new accounts within 30 days of the first deposit.⁴

The 90-day window covers most everyday debit card use. If you swiped, tapped, or entered your card number at a checkout, the dispute falls into the longer timeline. The 45-day window applies mainly to ATM errors and direct electronic transfers.

When the bank posts provisional credit and keeps investigating, it must notify you that the credit was issued and that the investigation is ongoing.²

What Happens When the Investigation Ends

Two outcomes are possible, and the consequences run in opposite directions.

If the Bank Sides With You

The provisional credit becomes permanent. You keep the funds, TD Bank sends written confirmation that the dispute was resolved in your favor, and you don’t have to do anything else.

If the Bank Denies the Dispute

TD Bank reverses the provisional credit by debiting your account for the same amount. Within three business days of finishing the investigation, the bank has to send you a written explanation of its findings, along with notice of your right to request copies of every document it used to reach that decision.¹ Request those documents. They’re the only way to see the basis for the denial and decide whether to escalate.

If you’ve already spent the provisional credit, the reversal can put your account in the negative. For five business days after notifying you of the reversal, TD Bank must honor checks and preauthorized transfers from your account without charging overdraft fees.² Standard overdraft rules apply after that.

Getting Provisional Credit Starts With Reporting the Dispute

None of this happens until you notify the bank. You can call TD Bank’s 24-hour customer service line at 1-888-751-9000, visit a branch, or file the dispute through online banking. Have your account number, the exact date and amount of the transaction, and the merchant or location ready. Be specific about why the charge is wrong: unauthorized, duplicated, or a different amount than you agreed to.

The outer deadline for reporting is 60 days from the date TD Bank sends the statement that first shows the disputed transaction. Miss that window and you lose most of the federal protections, including the right to provisional credit.²

How fast you report also controls how much of an unauthorized transaction you can be held liable for. Regulation E sets tiered caps:

Report within 2 business days of discovering the loss or theft, and liability is capped at $50 or the amount of unauthorized transfers that occurred before you notified the bank, whichever is less.⁵
Report after 2 business days but within 60 days of the statement, and the cap climbs to $500.
Report after 60 days from the statement, and liability is unlimited for unauthorized transfers occurring after the 60-day window closes.⁶

The two-business-day clock starts when you learn of the loss or theft, not when the fraudulent charge posts. The day of discovery doesn’t count, and weekends and holidays don’t count.⁵

What Provisional Credit Doesn’t Cover

Two situations that people commonly assume are covered aren’t.

Credit card disputes follow a different federal law. If the disputed charge is on a TD Bank credit card, the Fair Credit Billing Act and Regulation Z apply, not Regulation E. There’s no provisional credit in that process because the money was never taken from your account in the first place; you’re allowed to withhold the disputed portion of your bill while the issuer investigates, and the creditor has up to two complete billing cycles or 90 days to resolve it.⁷

Business accounts aren’t covered either. Regulation E only protects accounts established primarily for personal, family, or household purposes. Disputes on a TD Bank business checking or savings account fall outside the provisional-credit rules, the investigation timelines, and the liability caps described here.⁸ Your rights come from the account agreement and the Uniform Commercial Code instead.

If TD Bank Denies Your Dispute

Ask for the documents. The written explanation the bank owes you includes notice of your right to receive copies of the records it relied on, and reviewing them is the only way to see whether the denial rests on incomplete or misread information.

If you still believe the denial was wrong, you can file a complaint with the Consumer Financial Protection Bureau at consumerfinance.gov/complaint. Describe the problem, include the key dates and amounts, and attach supporting documents such as statements and the bank’s denial letter. Companies generally respond within 15 days, though complex cases can take up to 60.⁹ A complaint doesn’t guarantee reversal, but it puts the dispute in front of a federal regulator.

1
Office of the Law Revision Counsel. 15 USC 1693f – Notification of and Adjustment for Errors
2
Consumer Financial Protection Bureau. 12 CFR 1005.11 – Procedures for Resolving Errors
3
eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
4
eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
5
Consumer Financial Protection Bureau. 12 CFR 1005.6 – Liability of Consumer for Unauthorized Transfers
6
eCFR. 12 CFR 1005.6 – Liability of Consumer for Unauthorized Transfers
7
Consumer Financial Protection Bureau. 12 CFR 1026.13 – Billing Error Resolution
8
Consumer Financial Protection Bureau. Electronic Fund Transfers FAQs
9
Consumer Financial Protection Bureau. Submit a Complaint