A charge on a credit card statement that the cardholder never made does not stay disputable forever. Federal law sets a window for telling the card company about a billing error, and the window is counted from a statement, not from the purchase or from the day the charge was noticed. Once the window closes, the legal protections attached to it can be lost.
The question for a cardholder who spots an unfamiliar charge is how long there is to dispute it. Under the Consumer Financial Protection Bureau’s text of Regulation Z, the answer is 60 days from the statement that first shows the error, and the notice has to arrive within that period.
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Sixty days start with the first statement that shows the error
Regulation Z, reproduced on the CFPB’s billing-error rule page, says the consumer’s notice must reach the creditor’s disclosed address “no later than 60 days after the creditor transmitted the first periodic statement that reflects the alleged billing error.”
Two details follow from that wording. The clock does not start on the day of the transaction, and it does not start when the cardholder finally notices the charge. A fraudulent charge that appears on a statement mailed in early October puts the deadline in early December, whenever it is spotted.
What counts as a billing error
The rule lists several. An unauthorized charge is one: an entry for credit extended to someone who lacks actual, implied or apparent authority to use the account. Goods or services the consumer did not accept, or that were not delivered as agreed, also qualify.
The list continues with a failure to credit a payment properly, computational mistakes by the creditor, and entries the consumer asks the creditor to clarify. A statement that never arrived at a known address, received at least 20 days before the billing cycle ended, is covered too. A request for receipts kept only for tax or record purposes is not.
The notice has to be in writing
The regulation requires a written notice. It must identify the consumer’s name and account number, or enough information to do so, and to the extent possible state the belief that a billing error exists, the reasons for it, and the type, date and amount of the error.
Because the notice must arrive within the 60 days, mailing it on the final day is a gamble. Sending it well inside the window, to the billing-error address printed on the statement rather than the payment address, and keeping a dated copy, puts the proof on the cardholder’s side if the timing is ever questioned.
What the card company must do, and by when
The creditor must send a written acknowledgment within 30 days of receiving the notice, unless it has already finished resolving the dispute in that time. It then has to complete its procedures “within 2 complete billing cycles (but in no event later than 90 days) after receiving a billing error notice.”
Two billing cycles is the rule the regulation leads with, and 90 days is the hard backstop. A card issuer that runs past both has broken the regulation, and the written notice and its date become the evidence.
Protections while the dispute is open
While a billing error notice is pending, the rule bars the creditor from trying to collect the disputed amount, and the consumer does not have to pay that portion. The creditor also may not make or threaten an adverse report to anyone about the disputed amount.
Nor may it accelerate the debt, or restrict or close the account, simply because the consumer used these rights in good faith. Disputes over debit card and bank transfer errors follow a different regulation, with its own timetable, on the CFPB’s Regulation E page. Mistakes on a credit report, which are a separate matter, are covered in the CFPB’s guide to disputing them.
With a charge on the card nobody made, has the 60-day notice window started?
A cardholder who sets an unfamiliar charge aside and pays the statement anyway can discover that the 60 days ran out while the question was still open. The notice date is what the dispute rests on, and a vague phone call leaves little to show for it.
50 Letters to SSA, IRS, Banks & Insurers includes bank letters for unauthorized transfers and card disputes, written as fill-in letters. Each comes with when to send it, where, the deadline and what to enclose, and the back of the book has a mailing log for recording the date a notice went out.
This article was produced with AI assistance and edited for accuracy against the sources linked above.
