Q: Can a financial institution require a consumer to file a police report or other documentation as a condition of initiating an error resolution investigation?
(UPDATED 6/4/2021): No. A financial institution must begin its investigation promptly upon receipt of an oral or written notice of error and may not delay initiating or completing an investigation pending receipt of information from the consumer. See Comments 11(b)(1)-2 and 11(c)-2. In the past, Bureau examiners found that one or more financial institutions failed to initiate and complete reasonable error resolution investigations pending the receipt of additional information required by the institution. These examples can be found in the Bureau’s Summer 2020 edition of Supervisory Highlights
and Fall 2014 edition of Supervisory Highlights
. The Bureau cited similar violations in 2019-BCFP-0001