Consumer complaint received 2025-10-07 00:00:00
Product: Checking or savings account — Checking account
Issue: Problem with a lender or other company charging your account — Transaction was not authorized
Company: JPMORGAN CHASE & CO.
State: MD

Complaint narrative:
I am writing in direct response to the companys XX/XX/year> reply stating my claim was Closed with explanation and partially denied due to an alleged out-of-recovery timeframe under the 60-day liability rule. This response is legally insufficient and noncompliant with the Electronic Fund Transfer Act ( EFTA ) and Regulation E ( 12 CFR 1005.11 ). 

1. The Bank Misapplied the 60-Day Liability Rule The 60-day liability rule applies only to limiting consumer liability, not to deny the banks obligation to investigate and correct unauthorized transfers. Under 12 CFR 1005.11 ( b ) ( 1 ), once a consumer provides oral or written notice of error, the financial institution must conduct a reasonable investigation, regardless of when the transaction occurred. A delay beyond 60 days may affect consumer liability for subsequent unauthorized transactions, but does not eliminate the banks duty to investigate and resolve the originally reported unauthorized transactions. 

2. The Banks Out of Recovery Time Frame Excuse Is Invalid Equating the 60-day reporting window with an out-of-recovery time frame is not supported by Regulation E. There is no provision that allows a financial institution to deny a claim simply because they are unable to recover funds. The regulation requires the bank to credit the consumers account for unauthorized transactions once confirmed, regardless of merchant reimbursement. Recovery from the merchant or acquirer is the banks internal issue, not a condition precedent to honoring the consumers claim. 

3. Partial Denial Contradicts Their Own Findings The banks own response confirms the transactions were recognized as potentially unauthorized, evidenced by the issuance of provisional credits and refiling of certain claims ( e.g., XXXX XXXX XXXX ). This acknowledgment of error triggers full Regulation E protections. Selective approval or denial of transactions under the same claim violates 12 CFR 1005.11 ( c ) ( 1 ), which requires a consistent and good-faith investigation for each reported error. 

4. Failure to Provide Adequate Notice and Documentation Per 12 CFR 1005.11 ( d ), if a financial institution determines no error occurred, it must provide a written explanation of the findings and documentation upon request. The banks Closed with explanation notice is conclusory, lacking documentary evidence or reasoning sufficient to demonstrate a reasonable investigation. I hereby request copies of all evidence relied upon to deny the {$220.00} transaction, including : The full investigation log and decision rationale ; Any merchant/acquirer responses received ; Copies of the statements and internal correspondence used in determining timeliness. 

5. Good Faith & Fair Dealing The Deposit Account Agreement and EFTA require the bank to act in good faith and fair dealing. Denying a legitimate unauthorized claim on procedural grounds unsupported by statute constitutes bad faith and unfair practice, which falls squarely under CFPB enforcement authority.

Demand for Relief : Immediate reconsideration and reversal of the denial for the {$220.00} unauthorized transaction ; Full reimbursement ( final credit ) for all disputed unauthorized transactions ( {$190.00}, {$200.00}, {$220.00}, and {$160.00} ) ; Delivery of complete investigation documentation under 12 CFR 1005.11 ( d ) ; Confirmation of compliance within 10 business days of receipt of this rebuttal.

If the bank fails to provide documented proof of a reasonable investigation or continues to rely on incorrect interpretations of Regulation E, I will pursue further CFPB escalation and formal complaint referral to the OCC and FTC for noncompliance. 

Sincerely,

Company response to consumer: Closed with explanation