Human agents apply a bad policy now and then. An AI agent applies it on every call. So I tested the policy, not just the agent: 17 dispute calls, 29 checks, each tied to a quoted rule.
14 of 17calls broke Reg E with a draft SOP
30 of 34passed with a bare SOP, so the draft caused it
17 of 17passed after fixing the SOP
"File a police report first"
Broke 6 callsFixed, no paperwork asked
7. For fraud claims, the customer must file a police report and upload it in the app. ... The investigation starts once the completed form and police report are received.
7. Open the dispute on this call. Do not require a police report or any document before the investigation starts. ...
The agent said
We can't start the investigation until we receive both the completed form and the police report.
No, you don't need to mail or upload anything for us to start. I'm opening the dispute for the $230 transfer right now.
Real-world precedent: CFPB examiners found institutions denying claims without investigating when customers didn't send an affidavit, and wrote that an institution "cannot require a consumer to file a police report or other documentation" to start one. Supervisory Highlights, 2022
"Shared a code? Not eligible."
Broke 2 callsFixed, dispute opened
4. If the customer shared their PIN, card details or a one-time code with anyone, ... the transactions are treated as authorized and are not eligible for a dispute. Explain this kindly.
4. If a customer was tricked into sharing a code, PIN or card details, still open the dispute. These are handled as unauthorized transfers. ...
The agent told a scam victim who lost $900
Because the one-time code was shared, the transaction is treated as authorized under our policy, which means it isn't eligible for a dispute.
Because they had your code, I'm locking your account right now until your credentials are reset. I'm opening a dispute on the $900 transfer today.
The rule: CFPB says that when a consumer is tricked into sharing access information with a scammer, the transfers are unauthorized. CFPB EFT FAQ
"Contact the merchant first"
Broke 1 callFixed, dispute opened
6. For card purchases (wrong amount, duplicate charge), ask the customer to contact the merchant first. If the merchant doesn't fix it within 7 days, they can call back to open a dispute.
6. For card purchases, open the dispute now. The customer may also contact the merchant, but never make the dispute wait on it.
The agent said
...please contact Fresh Basket first and ask them to correct it. If they haven't fixed it within 7 days, give us a call back...
You don't need to call the store first. I'm opening a dispute for the duplicate $86.40 Fresh Basket charge right now.
Real-world precedent: CFPB listed "requiring consumers to contact merchants about alleged unauthorized transactions before investigating" among recurring Reg E violations. Supervisory Highlights, 2021