Replay of a real run — captured 10 Jul 2026
Arbiter
Card Dispute Adjudication Agent
Every step below is a real trace event from the signed run ledger.
sc-arbiter
Transcript
I'll kick off the first two independent calls — reading the dispute and checking the regulatory clock — simultaneously.
The timeline check is dispositive. Here's what the record shows:
| Clock fact | Value |
|---|---|
| Regime | Reg E |
| Notice date | 2026-04-20 |
| Days elapsed (to 2026-06-24) | 47 days |
| Provisional-credit / resolution deadline | 2026-06-04 |
| Breached? | YES |
The bank blew past its Reg E deadline by 20+ days with no resolution recorded. Under 12 CFR 1005.11(c)(1)-(2), when [prompt-template text withheld] it must provisionally credit the account, and must resolve within 45 calendar days. Both clocks are blown here. The merits do not save the bank — I proceed directly to adjudication without pulling transaction or merchant evidence.
The decision brief
Adjudication — D3 | Reg E | PROVISIONAL CREDIT
Ruling
| Field | Value |
|---|---|
| Dispute | D3 |
| Regime | Reg E (12 CFR 1005.11) |
| Ruling | pass Provisional Credit |
| Liability party | Bank |
| Within timeline? | fail No |
Reason Codes
timeline-breach · provisional-credit-clock · reg-e-11c-violation · no-resolution-recorded
Rationale
The cardholder filed on 2026-04-20, reporting an unauthorized $1,150 ATM withdrawal and noting two months of silence from the bank. As of the reference date 2026-06-24, 47 days have elapsed against a resolution deadline of 2026-06-04 — the bank is over 20 calendar days past the hard deadline with no resolution on record.
Reg E imposes two mandatory clocks:
- 10 business days to complete the investigation, or else provisionally credit the account (12 CFR 1005.11(c)(1)).
- 45 calendar days outer limit for resolution (12 CFR 1005.11(c)(3)).
Both are blown. The timeline-dominates rule is absolute: no matter how the merits might otherwise cut, a breached Reg E clock requires provisional credit and places liability on the bank for the procedural failure. Transaction evidence and merchant evidence were not consulted — they are irrelevant once the clock is breached.
🚨 Escalation flag: The senior disputes oversight function should investigate the operational breakdown that allowed a consumer Reg E complaint about a $1,150 ATM fraud to go 47 days without resolution or provisional credit. This represents a potential CFPB exam finding.