When money disappears from a debit card account or payment app, many people assume the hardest part is spotting the fraud. In reality, the reimbursement fight often turns on what happens next. A missed deadline, a vague complaint, or a poorly documented follow-up can quietly weaken a claim that otherwise looked legitimate.
That matters because payment fraud is not rare. The Federal Trade Commission reported that consumers said they lost more than $12.5 billion to fraud in 2024, and the biggest aggregate losses were tied to bank transfers and payments rather than credit cards. The FTC’s 2024 data book likewise shows bank transfers and payments producing the highest reported aggregate losses. (FTC consumer alert, FTC data book PDF)
For consumers dealing with unauthorized debit card transactions, ACH withdrawals, or app-based transfers, federal law can provide important protections. The Electronic Fund Transfer Act and Regulation E include rules on liability limits and error resolution for many electronic fund transfers, including procedures tied to unauthorized transfers and investigation timelines. (CFPB Regulation E overview, CFPB Section 1005.6, CFPB Section 1005.11)
In this post, you’ll learn five common payment dispute mistakes that can undermine reimbursement, why banks and apps focus on them, and how an attorney may help when a claim stalls or gets denied. If you want a broader overview of the rules that often shape these cases, this guide on how debit card and payment app disputes usually work provides useful background.
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Many consumers think of a dispute as a simple fraud report: “I didn’t make this charge.” But banks and payment platforms often evaluate several separate issues at once:
That legal framing matters. Under 12 C.F.R. § 1005.6, a consumer’s liability for unauthorized electronic fund transfers is limited in many circumstances, but timing plays a major role. Under 12 C.F.R. § 1005.11, financial institutions generally have defined procedures for investigating reported errors, including unauthorized EFTs, and those procedures are tied to deadlines and notice requirements. The regulation also explains that a late notice may affect whether the institution has to follow those error-resolution procedures. (CFPB Section 1005.6, CFPB Section 1005.11, Cornell LII text of 12 C.F.R. § 1005.11)
In other words, reimbursement disputes are often won or lost on process.
The most common problem is delay.
Under Regulation E, a consumer generally has to report an unauthorized transfer appearing on a periodic statement within 60 days after the institution sends that statement in order to avoid potential liability for additional unauthorized transfers occurring after that period. The regulation also links the bank’s formal error-resolution duties to timely notice. (CFPB Section 1005.6, CFPB Section 1005.11)
There is also a separate timing concept involving a lost or stolen access device. If a debit card or similar access device is lost or stolen, reporting quickly can affect the amount of potential consumer liability under Regulation E. (CFPB Section 1005.6)