Regulatory Requirements

Federal regulations impose requirements on how you must handle certain types of disputes, particularly those involving consumer accounts.

Which Regulation Applies to Your Program?

Account Type	Funding Source	Examples	Applicable Regulation
Consumer Prepaid	Cardholder's own funds loaded onto card	GPR prepaid cards, payroll cards, benefit cards	Regulation E (EFTA)
Consumer Debit	Cardholder's own funds in bank account	Debit cards	Regulation E (EFTA)
Consumer Credit	Borrowed funds (credit line)	Credit cards, charge cards	Regulation Z (TILA)
Consumer BNPL	Borrowed funds (installment loan)	Buy-now-pay-later, installment plans	Regulation Z (TILA)
Commercial/Business	Any	Corporate cards, fleet cards	None (network rules only)

Regulation E applies when disputing transactions using the consumer's own funds. Regulation Z applies when disputing transactions using borrowed funds.

Regulation E Dispute Timelines

Please note that your program is responsible for sending required communications, issuing or reversing provisional credits, and fulfilling all other Regulation E requirements, unless otherwise configured during implementation.

Timeframe	Milestone
0-60 calendar days after cardholder's bank statement containing error is transmitted	The cardholder submits a dispute to the card program manager. Card program Customer Support Team completes dispute intake using their Lithic Dashboard.
0-10 business days after dispute is submitted to Lithic for accounts open longer than 30 days	Acknowledgment of receipt of dispute is transmitted to the cardholder. Though the timeframe is up to 10 days, communication is typically sent instantaneously.
0-10 business days after dispute is submitted to Lithic for accounts open longer than 30 days	The Dispute decision engine determines the following: • Chargeback eligibility • Write-off decision based on threshold set in the dispute configuration setup.
0-10 business days after dispute is submitted to Lithic for accounts open longer than 30 days	Provisional credit is issued.
0-20 business days after dispute is submitted to Lithic on an account opened within the last 30 days or a transaction occurring at a foreign POS	The Dispute decision engine determines the following: • Chargeback eligibility • Write-off decision based on threshold set in the dispute configuration setup.
0-45 calendar days after dispute is submitted to Lithic for an unauthorized EFT	If the investigation is not completed within 10 business days of receiving notice of error from the cardholder, then the investigation may be extended to 45 calendar days.
0-90 calendar days after the dispute is submitted to Lithic	Dispute is denied.
0-3 business days after dispute is denied	Notice of denial and provisional credit reversal is transmitted.
5+ business days after notice of dispute denial is transmitted	Provisional credit is reversed.
0-90 calendar days after the dispute is submitted to Lithic for debit card transactions and remittances	Dispute is won. Provisional credit is now a final credit.
0-3 business days after dispute is won	Notice of resolution is transmitted. This notice is typically transmitted instantaneously.
0-120 days after the dispute is submitted to Lithic	If the acquirer challenges the chargeback, the recovery attempt process can be extended to 120 days.

Regulation Z Dispute Timelines

Please note that your program is responsible for sending required communications, statement adjustments, and fulfilling all other Regulation Z requirements, unless otherwise configured during implementation.

Timeframe	Milestone
0-60 calendar days after the creditor transmitted the first periodic statement containing the error	The cardholder submits a dispute to the card program manager. Card program Customer Support Team completes dispute intake using their Lithic Dashboard.
0-30 calendar days after dispute is submitted to Lithic	Acknowledgment of receipt of dispute is transmitted to the cardholder. Though the timeframe is up to 30 days, communication is typically sent instantaneously.
0-10 calendar days after dispute is submitted to Lithic	The Dispute decision engine determines the following: • Chargeback eligibility • Write-off decision based on threshold set in the dispute configuration setup.
0-2 complete billing cycles (maximum 90 days) after dispute is submitted to Lithic	The following outcomes happen within this timeframe: • Investigation is completed • Chargeback is processed • Chargeback may be resolved • Funds may be recovered
0-2 complete billing cycles (maximum 90 days) after dispute is submitted to Lithic	Dispute is denied.
0-2 business days after the dispute is denied	Notice of denial and statement adjustment is sent.
0-90 calendar days after the dispute is submitted to Lithic	Dispute is won. Statement adjustment is permanent.
0-120 days after the dispute is submitted to Lithic	If the acquirer challenges the chargeback, the recovery attempt process can be extended to 120 days.

Non-Regulation Dispute Timelines

Please note that card network rules still apply.

Timeframe	Milestone
After the transaction settles on the cardholder's account	The cardholder must submit a dispute to the card program manager. Card program Customer Support Team completes dispute intake using their Lithic Dashboard.
0-5 days after submitting a dispute to Lithic	The Dispute decision engine determines the following: • Chargeback eligibility • Write-off decision based on threshold set in the dispute configuration setup.
0-120 days after dispute is submitted to Lithic	Below are all actions that happen within this timeframe: • Fraud investigation (if relevant) • Dispute is written off • Or dispute denied: ◦ No error occurred ◦ Outside chargeback timeframes • Or recovery attempted through chargeback process. If the acquirer challenges the chargeback, the recovery attempt process can be extended to 120 days. Dispute will eventually resolve as won or lost.