Dispute and complaint triage
Three regimes, three clocks, one queue.
What goes wrong
A dispute queue is three regulatory regimes wearing one interface. An unauthorised debit is Reg E, with a 10-business-day provisional-credit trigger and a 45-day outer limit. A card billing error is Reg Z, acknowledged within 30 days and resolved within two cycles. A credit-reporting dispute is the FCRA, reinvestigated within 30 days.
Triage agents are good at this classification and that is exactly the risk: a misrouted dispute does not fail loudly, it starts the wrong clock. The consumer gets a correct-looking response under the wrong regime, and the deadline that actually applied passes unnoticed.
The sharper failure is closure. An agent that resolves a dispute against the consumer without a recorded investigation has produced the single finding every one of these statutes is built to prevent -- and it will do it at a scale no manual process ever could.
Who runs this today
- Card issuers and banks triaging Reg E and Reg Z disputes at volume.
- Furnishers handling FCRA reinvestigation requests through an automated intake.
- Complaint-handling teams routing CFPB portal complaints into operational workflows.
Which controls apply
6 rules ship with the DISPUTE_TRIAGE template. Every
threshold is a number from a published rule, so a model-risk reviewer can
read the value and open the CFR rather than asking how it was fitted.
None of these rules decides credit.
| Control | Authority | Verdict |
|---|---|---|
| Reg E Provisional Credit Within 10 Business Days Where a Reg E investigation runs past 10 business days, the institution must provisionally credit the disputed amount while it continues. | Reg E 12 CFR 1005.11(c)(2)(i) | ESCALATE |
| Reg E Investigation Completed Within 45 Days The outer limit for a Reg E investigation is 45 days (90 for certain new-account, point-of-sale and foreign transactions). | 12 CFR 1005.11(c)(3) | BLOCK |
| Reg Z Billing Error Acknowledged Within 30 Days A creditor must acknowledge a billing error notice within 30 days of receipt. | Reg Z 12 CFR 1026.13(c)(1) | ESCALATE |
| Reg Z Billing Error Resolved Within 90 Days Resolution is due within two complete billing cycles and in no event later than 90 days after receipt. | Reg Z 12 CFR 1026.13(c)(2) | BLOCK |
| FCRA Reinvestigation Within 30 Days A consumer dispute of credit report accuracy must be reinvestigated within 30 days of receipt. | 15 U.S.C. 1681i(a)(1)(A) | BLOCK |
| No Dispute Closure Without An Investigation Closing a dispute as unsubstantiated without a recorded investigation is the failure mode an automated triage agent introduces, and it is what turns a servicing workflow into an enforcement action. | Reg E 12 CFR 1005.11(c) | BLOCK |
What the evidence looks like
The sample below is a real BLOCK on a dispute closed with no investigation recorded -- the specific failure an automated triage agent introduces, and the one that reads worst in an exam.
Sample evidence bundle
A real bundle from this template, exported through the same endpoint a customer would use. It carries the decision, the failed rules with their reasons, and the hash-chained audit events. You can verify it yourself without installing anything from us — the verifier is standalone and imports nothing from Sentinel.
A sensible pilot
The other three
The same gate governs all of them. Start where a wrong answer is recoverable, and move to credit decisioning when the evidence earns it.
Start in shadow mode
We are taking three design partners. Every deployment starts in OBSERVE, which evaluates everything and enforces nothing, so the first month costs you a report rather than a risk.
See the programme