(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. For example, in 2019-BCFP-0001
, the Bureau found that the practice of requiring a consumer to contact the merchant before initiating an error resolution investigation was a violation of Regulation E. Similarly, the Fall 2014 edition of Supervisory Highlights
discussed instances where examiners found that one or more financial institutions had instructed consumers to contact the merchant instead of promptly initiating an error investigation.