B-6 Investigations of unauthorized credit and debit card transactions
This bulletin reiterates the expectations of the Financial Consumer Agency of Canada (FCAC) with respect to the investigations of alleged unauthorized credit and debit transactions. Federally regulated financial institutions (FRFIs) must take all relevant factors into account prior to finding a consumer liable, regardless of the method or technology used to process a credit or debit card transaction.
Specifically, FRFIs must investigate whether circumstances beyond the cardholder’s control resulted in an unauthorized transaction (such as shoulder-surfing, coercion, card theft, systems malfunction, etc.). FRFIs must not rely solely on authentication technologies to truncate or eliminate a comprehensive investigation of an alleged unauthorized transaction. For example, a finding of liability cannot solely be based on the fact that a transaction was completed using the correct chip-and-PIN combination.
FCAC will continue to scrutinize cardholders’ claims of unauthorized transactions and expects FRFIs to report on the specific investigative steps taken before issuing a finding of liability against a cardholder.
Thank you for your ongoing cooperation.
Financial Consumer Agency of Canada
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