Account Adjustment Notice: Billing Errors and the 60-Day Rule

An account adjustment notice tells you a bank or card issuer has changed the balance on your account, either as a charge or as a credit, and if the change looks wrong you generally have 60 days from the statement date to dispute it in writing and preserve your federal protections.¹ For debit card and bank account adjustments the same 60-day clock applies, and missing it can leave you liable for the full amount of any unauthorized transfers that happened after the window closed.²

Read the Notice Like Evidence

Before you decide anything, pull four pieces of information off the notice and save it. You want the reference or case number, which you’ll need on every follow-up. The effective date of the adjustment, because that starts several clocks. The exact dollar amount, and whether it’s a charge or a credit. And the contact information for the billing inquiry department, which is not the same as the payment address. Sending a dispute to the payment address can undermine your rights before you’ve even started.

Then compare the amount to your own records: bank statements, receipts, screenshots, prior correspondence. A credit you didn’t expect is not always good news, and a charge you don’t recognize is not always fraud. You’re trying to answer one question: does the adjustment match reality?

Why You Might Have Received One

Most adjustment notices come from one of three situations, and knowing which one you’re in shapes what to do next.

The first is a straightforward correction. A merchant posted a charge twice, a payment was applied to the wrong account, or a promotional rate wasn’t reflected. The institution reverses the entry and the notice documents that reversal. Usually there’s nothing to dispute.

The second is the outcome of a fraud investigation. When you report an unauthorized charge, the institution often issues a temporary credit while it looks into it. If the claim is confirmed, that credit becomes permanent. If it’s denied, the credit is reversed and the charge reappears. Either result generates an adjustment notice. This is where people get burned most often, because a temporary credit feels like a resolution and it isn’t. The matter is closed only when the final adjustment notice confirms a permanent correction.

The third is regulatory remediation. When a regulator finds that a fee or practice was improper, the institution may be required to refund customers across many accounts at once. If you received a credit you didn’t ask for, and the notice references a regulatory action or compliance review, that’s usually the source. These almost never need to be disputed.

What Federal Law Treats as a Billing Error

The Fair Credit Billing Act only kicks in when the adjustment involves what the statute calls a “billing error.” Whether your situation fits determines how much leverage you actually have.

Charges you didn’t make, or charges for an amount different from what you agreed to.
Goods or services that were never delivered, or that you refused in line with the original agreement.
Payments or refunds the creditor didn’t properly credit.
Math or accounting mistakes on the statement.
Statements the creditor failed to send to your current address, if you provided that address at least 20 days before the billing cycle ended.
Charges you’ve asked for documentation or explanation on and haven’t received.

If your dispute falls into one of these categories, the creditor has to follow a specific investigation procedure once you file a written notice.¹ If it doesn’t, you can still challenge the charge directly with the institution or escalate to a regulator, but the FCBA’s procedural protections won’t apply.

Disputing a Credit Card Adjustment in Writing

A phone call is not a formal dispute. To get the full protection of the FCBA, you need to send a written notice to the creditor’s billing inquiry address, which is printed on your statement.¹ Include your name, your account number, the dollar amount you believe is wrong, and an explanation of why. Attach copies of supporting documents, never originals. Send it by certified mail with return receipt requested so you have proof of when the creditor received it.

The 60-Day Clock

Your written notice must reach the creditor within 60 days after it sent the first statement showing the error.¹ The clock runs from the date the statement was sent, not from the date you opened your mail or logged in. Miss the window and you don’t lose your ability to complain, but you lose the specific procedural rights the FCBA gives you, including the right to withhold payment during the investigation.

What You Can Withhold

Once you’ve filed a proper written dispute, you don’t have to pay the disputed portion of your balance, including the related minimum payment and finance charges, while the investigation is pending. You still owe anything on the account that isn’t in dispute, and you should keep paying that part to avoid late fees on the undisputed balance.¹

What the Creditor Must Do After You File

The creditor has 30 days to send you a written acknowledgment that it received your dispute. It can skip the acknowledgment if it resolves the whole thing inside those 30 days.¹ The full investigation has to be finished within two complete billing cycles and no later than 90 days from receipt of your notice. During that time, the creditor cannot try to collect the disputed amount.

Your credit is protected too. While the dispute is pending, the creditor cannot report the disputed amount as delinquent to any credit bureau. It can note that the amount is in dispute, but it can’t threaten your credit standing over your refusal to pay a contested charge.³

If the creditor confirms your dispute, it has to correct the account and refund any finance charges caused by the incorrect billing, and you’ll get a written explanation of the correction.¹ If it sides against you, it has to send you a written explanation and, on request, copies of the documents it relied on. From that point, you get at least 10 days to pay before the creditor can report you as delinquent or add late fees. If you still disagree, a follow-up written notice preserves your right to have any credit reporting on that balance flagged as disputed, along with a list of everyone the creditor reports it to.³

Debit Card and Bank Account Adjustments Are Different

Debit cards and bank accounts don’t fall under the FCBA. They’re governed by the Electronic Fund Transfer Act and Regulation E, and the protections are weaker in ways that matter.

You still have 60 days from the statement date to report an error, but Regulation E accepts either an oral or a written notice.⁴ The bank can ask you to follow an oral report with a written confirmation within 10 business days, and failing to send that confirmation can limit what the bank has to do next.

The bank then has 10 business days to investigate and resolve the error. It can extend the investigation to 45 calendar days, but only if it provisionally credits your account within those first 10 business days and gives you full access to the funds.⁵

How Much You’re on the Hook For

Unauthorized debit card liability is tiered by how quickly you act:

Report within 2 business days and your liability is capped at $50, or the amount of the unauthorized transfers before you notified the bank, whichever is less.
Report after 2 business days but within 60 days of your statement, and your liability can climb to $500.
Report more than 60 days after the statement was sent, and you’re responsible for every unauthorized transfer that happened after that 60-day window closed, with no cap.²

Credit card liability is far more forgiving. Your maximum exposure for unauthorized use of a credit card is $50, and once you report the card lost or stolen you owe nothing for charges made after the report.⁶ Most major issuers waive the $50 as a matter of policy, though they’re not required to.

If the Creditor Ignores the Rules or Denies a Valid Dispute

People often overestimate the penalty for a creditor that mishandles an investigation. If the creditor fails to acknowledge your dispute, misses the 90-day investigation deadline, or otherwise violates FCBA procedure, it forfeits the right to collect the disputed amount and related finance charges. That forfeiture is capped at $50, no matter how large the underlying charge was.¹

The stronger remedy is a private lawsuit. For FCBA violations you can recover actual damages plus twice the finance charge on the disputed amount, with a statutory floor of $500 and a ceiling of $5,000 for open-end credit accounts, and a court can award your attorney’s fees and court costs.⁷ Small claims court is a practical venue for smaller matters; filing fees generally run between $15 and $375 depending on jurisdiction. The statutory minimum means you can come out ahead even after costs if you can show the creditor broke procedure.

Short of a lawsuit, you can file a complaint with the Consumer Financial Protection Bureau. You describe the problem in your own words, attach up to 50 pages of supporting documents, and identify the company. The CFPB forwards the complaint, and the company typically responds within 15 days, though more complex matters can take up to 60.⁸ The complaints are tracked and published in a public database, which changes the calculus for a bank that denied a borderline dispute.

A Note on Taxes

Routine adjustments, like the reversal of a billing error or a refund from a merchant, don’t create a tax obligation because they’re restoring money that was already yours. Interest is different. If a bank pays you interest as part of a remediation, that interest is taxable, and institutions must report interest payments of $10 or more on Form 1099-INT.⁹ If you receive a large regulatory remediation credit with an interest component, expect that form at tax time.

1
Office of the Law Revision Counsel. 15 USC 1666 – Correction of Billing Errors
2
eCFR. 12 CFR 1005.6 – Liability of Consumer for Unauthorized Transfers
3
Office of the Law Revision Counsel. 15 USC 1666a – Regulation of Credit Reports
4
Consumer Financial Protection Bureau. 12 CFR 1005.11 – Procedures for Resolving Errors
5
eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
6
Office of the Law Revision Counsel. 15 USC 1643 – Liability of Holder of Credit Card
7
Office of the Law Revision Counsel. 15 USC 1640 – Civil Liability
8
Consumer Financial Protection Bureau. Learn How the Complaint Process Works
9
Internal Revenue Service. About Form 1099-INT, Interest Income