Governance & Program Info

Dispute Resolution & Chargeback Processing — Governance

Cross-builder institution context and per-item ownership, due dates, status, and next actions for the governance-relevant checklist items in this builder.

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Checklist governance
Items (0 of 29 marked complete)
Annotate ownership, due date, status, and next action. Items on the left come from the builder's governance / compliance phases.
04 · Reg E / Reg Z Compliance & Quality
Enforce Reg E 10-business-day provisional credit timeline
required
12 CFR 1005.11(c)(2) requires provisional credit within 10 business days when the institution cannot complete investigation on time.
04 · Reg E / Reg Z Compliance & Quality
Enforce Reg E 45-day / 90-day final resolution timeline
required
45 days for most claims, 90 days for new accounts (30 days old or less) or foreign-initiated / POS-initiated transactions.
04 · Reg E / Reg Z Compliance & Quality
Enforce cardholder notification requirements
required
Reg E requires written notice of investigation results, and specific notices when provisional credit is retracted.
04 · Reg E / Reg Z Compliance & Quality
Track claim receipt timestamps across all intake channels
required
Reg E clocks start from oral or written claim receipt — phone, chat, email, in-app, and branch intake must share a single authoritative timestamp.
04 · Reg E / Reg Z Compliance & Quality
Enforce Reg Z 60-day cardholder billing-error window
required
12 CFR 1026.13 — cardholders have 60 days from statement date to assert billing errors on credit accounts.
04 · Reg E / Reg Z Compliance & Quality
Enforce Reg Z 30-day acknowledgment / 2-billing-cycle resolution
required
12 CFR 1026.13(c) — written acknowledgment within 30 days, resolution within 2 billing cycles (not more than 90 days).
04 · Reg E / Reg Z Compliance & Quality
Enforce Reg Z prohibition on adverse action during investigation
required
Issuers cannot report the disputed amount as delinquent or take collection action during the Reg Z investigation window.
04 · Reg E / Reg Z Compliance & Quality
Enforce Visa VCR cardholder claim window (120 days)
required
Visa cardholder claim window is typically 120 days from transaction; up to 540 days for certain fraud scenarios.
04 · Reg E / Reg Z Compliance & Quality
Enforce Visa representment window (Adyen 2025: 9 days US/Canada, 18 days other regions)
required
Adyen July 2025 changes compressed merchant representment response windows and introduced a tiered fee structure by response speed.
04 · Reg E / Reg Z Compliance & Quality
Enforce Mastercard MCOM timeline and arbitration windows
required
Mastercard 2025 arbitration changes eliminated the 10-calendar-day acquirer response window — acquirers must be ready at any time to accept financial responsibility.
04 · Reg E / Reg Z Compliance & Quality
Enforce VAMP ratio threshold compliance (2.2% → 1.5% April 2026)
required
Visa Acquirer Monitoring Program ratio drops to 1.5% for NA / EU / APAC from April 1, 2026 — automation must support ratio-aware intake and representment prioritization.
04 · Reg E / Reg Z Compliance & Quality
Enforce Compelling Evidence 3.0 eligibility assessment (auto-qualify October 2025)
required
Visa CE3.0 auto-qualification using Visa Secure or Visa Data Only became effective October 17, 2025 across all major regions.
04 · Reg E / Reg Z Compliance & Quality
Define dual-review policy for high-value disputes
required
Disputes above a dollar threshold or involving complex reason codes should require human review even when AI confidence is high.
04 · Reg E / Reg Z Compliance & Quality
Measure automation confidence calibration
recommended
Platt / isotonic calibration on the arbiter score so confidence thresholds map to true outcome probabilities — not raw model outputs.
04 · Reg E / Reg Z Compliance & Quality
Monitor decision reversal rate on human appeal
required
When a cardholder or merchant appeals, how often does human review reverse the AI's decision? Rising reversal is a drift signal.
05 · Governance & Compliance
Complete SR 11-7 model documentation for every pipeline model
required
Each of document intelligence, NLP classification, friendly-fraud scoring, win-probability scoring, rule-interpretation LLM, and arbiter needs its own SR 11-7 package.
05 · Governance & Compliance
Independent model validation for LLM rule-interpretation component
required
LLMs applied to consequential decisions require independent validation of rule-application accuracy, hallucination rate, and grounded-citation rate.
05 · Governance & Compliance
Ongoing model performance monitoring plan
required
Per-model KPIs, monitoring frequency, alert thresholds, and escalation paths — SR 11-7 requires the plan itself to be documented and approved.
05 · Governance & Compliance
Change management and model versioning
requiredtrinidy
Approvals, required testing, versioning, rollback procedure, and audit trail for every model update — including LLM prompt and fine-tuning changes.
05 · Governance & Compliance
Document Reg E (12 CFR 1005) compliance architecture
required
Map automation components to Reg E requirements — claim intake, investigation, provisional credit, final resolution, written notification.
05 · Governance & Compliance
Document Reg Z (12 CFR 1026) compliance architecture
required
Map automation components to Reg Z billing-error resolution — acknowledgment, investigation, resolution, adverse-action prohibition.
05 · Governance & Compliance
CFPB examination readiness package
required
Dispute sample, decision rationales, timing compliance metrics, and adverse-event logs ready for CFPB examiner on request.
05 · Governance & Compliance
Visa Compelling Evidence 3.0 (April 2023, auto-qualification October 2025)
required
Document the automation's CE3.0 eligibility assessment, evidence-assembly logic, and auto-qualification workflow.
05 · Governance & Compliance
Mastercard First-Party Trust Program
required
Document participation in and evidence-contribution workflow for Mastercard's first-party-fraud countermeasure program.
05 · Governance & Compliance
Visa VCR / Mastercard MCOM operating regulation compliance
required
Attestation that the automation's representment logic conforms to the current VCR and MCOM workflows and reason-code mappings.
05 · Governance & Compliance
VAMP and equivalent monitoring-program compliance reporting
required
Monthly / quarterly reporting against VAMP ratio thresholds and equivalent Mastercard programs — automation output feeds the ratio calculation.
05 · Governance & Compliance
Fair treatment analysis across protected classes
required
Disparate-impact assessment — are friendly-fraud or concede decisions correlated with geography, MCC, or device proxies for protected classes?
05 · Governance & Compliance
Explainability / reason-code output per decision
required
SHAP for scoring models plus grounded rule citations from the LLM — required for cardholder notification, merchant representment defense, and audit.
05 · Governance & Compliance
Board-level dispute-program reporting
recommended
Recovery rate, time-to-resolution, Reg E / Reg Z timing compliance, VAMP ratio, and fair-treatment metrics in board risk reporting.