Statement on Supervisory and Enforcement Practices Regarding Regulation Z Billing Error Resolution Timeframes in Light of the COVID-19 Pandemic
The Bureau is issuing this statement to inform creditors of the Bureau’s flexible supervisory and enforcement approach during the COVID-19 pandemic regarding the timeframe within which creditors complete their investigations of consumers’ billing error notices.
Specifically, in evaluating a creditor’s compliance with the maximum timeframe for billing error resolution set forth in Regulation Z, the Bureau intends to consider the creditor’s circumstances and does not intend to cite a violation in an examination or bring an enforcement action against a creditor that takes longer than required by the regulation to resolve a billing error notice, so long as the creditor has made good faith efforts to obtain the necessary information and make a determination as quickly as possible, and complies with all other requirements pending resolution of the error.
Good faith efforts that creditors may show include obtaining a reasonable estimate from the merchant of when it will be able to respond or determining reasonably that the merchant is unable to respond to the creditor’s request for information for the time being.
The Bureau does not expect, however, that current circumstances would prevent any creditor from fully complying with the requirements of § 1026.13(d).