WorkflowPayment Disputes & Fraud Claims

P2P Fraud Claims

P2P fraud and scam claims split payment by payment, each placed on its side of the line with the record that puts it there

Each payment placed on its side of the line, with the record that puts it there.

See one case, screen by screen ↓
demoDay 1of 10business days on the Regulation E clock when Marisol Ventura's claim was approved, with the recovery request filed the same minute
demo214claimswith the same facts, decided in the last 90 days, checked against her draft; 211 went the same way
target100%of placements cite the record that puts them there and are checked against similar decided claims
typical38%of reported P2P fraud repaid by the network's three largest owner banks in 2023, down from 62% in 2019
In short

What is P2P Fraud Claims?

P2P Fraud Claims is software for dispute teams that resolve P2P fraud and scam claims, separating unauthorized from induced payments. Seven agents rebuild each payment in a claim, place it as unauthorized under Regulation E or authorized but induced under the network's imposter-scam rule and the bank's policy, and draft the outcome, the letter and the recovery request. A claims specialist confirms each placement and a supervisor approves.

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Updated

The problem

Why P2P fraud claims get decided all or nothing

A P2P fraud claim usually mixes two kinds of payment. A payment a fraudster started, even with a passcode the customer was tricked into reading out, is an unauthorized electronic fund transfer: Regulation E makes the bank repay it, and the CFPB's Electronic Fund Transfers FAQs say so plainly. A payment the customer sent herself because someone lied to her is authorized but induced: Regulation E does not cover it, but the P2P network's imposter-scam rule, in force since June 30, 2023, and the bank's own claims policy may.

The facts that decide each payment sit in four systems: the digital banking platform's passcode and device logs, the P2P network gateway, the core banking system and the call transcript. A claims specialist copies them into case notes against a 10-business-day clock, then decides the whole claim at once. "You shared the code" becomes a wrongful denial, the recovery request reaches the receiving bank after the account is empty, and two customers with the same facts get different answers. P2P Fraud Claims puts seven agents in front of that gathering, so the specialist starts from each payment already rebuilt and placed, and decides.

typical12%of P2P scam claims repaid by the network's three largest owner banks in 2023
estimated20–40minutesa specialist spends gathering the facts for one claim, by hand
demo4systemshold the facts that decide one claim: passcode and device logs, the network gateway, the core and the call
Where a specialist's minutes on one claim goestimated
By hand56 minutes
With the solution8 minutes
  • Writing the claim up and starting the Regulation E clock8 → 1 min
  • Pulling each payment from the P2P network gateway8 → 0.5 min
  • Reading passcode, sign-in and device logs15 → 2 min
  • Reading the call transcript for what the customer says happened7 → 1 min
  • Deciding the outcome and writing the letter12 → 3 min
  • Filing the recovery request with the receiving bank6 → 0.5 min

Estimated split of one P2P fraud claim's specialist minutes, by hand and with the agents; gathering the facts by hand takes about 20 to 40 minutes a claim. Our estimate, kept modest.

How it works

How one claim is decided

Seven agents rebuild each payment, place it on its side of the line and draft the outcome; a specialist confirms, a supervisor approves.

What comes in
What it readsabout 3,900 claims a month · calls, passcode and device logs, network records, the core, the rules
Agents at work
Intake agentpayments and the clock
Then
Facts agentwho, which device, how
Then
Classification agentwhich side of the line
Consistency agenttwin claims
Then
Letter agentplain words, checked
Recovery agentnetwork request
Clock agent10 business days
A person decides
A claims specialist confirms each placement; a supervisor who did not work the claim approvesbelow 0.85 confidence, the specialist places the payment
What comes out
Each payment placed, cited
Credit, letter and recovery, approved
An examiner pack, masked
One case, step by step

One P2P fraud claim, from the fake fraud-department call to the money back

On October 20, Marisol Ventura, a Corvane National Bank customer since 2009, read a passcode to a caller posing as the bank's fraud department. Three payments left her checking account ending 2207. She called the bank the next morning. Here is her claim, P2P-26-041877, screen by screen in the working solution.

  1. 019:41 AM

    Each payment on its side of one dividing line

    Seven agents

    The agents read the call, rebuilt the three payments and placed each one in 4.2 seconds. Payments 1 and 2, $1,650.00 to J. Collier, sit on the left: unauthorized, Regulation E covers it, confidence 0.97. Payment 3, $750.00 to "CNB Account Protection", sits on the right: authorized but induced, the network rule and the bank's policy decide, confidence 0.93.

    Reg E · day 1 of 10 · due November 4 · final by December 5

  2. 02Minute by minute

    The afternoon rebuilt in three lanes

    Facts agent

    Twelve events from four systems, on one timeline: the caller, her own iPhone D-21C9 and a new device, D-7F3A. The passcode was entered on the new device from an IP address in Nevada, and both payments to J. Collier started there. At 2:31 PM she sent the third payment herself, signed in with Face ID from Ohio, because the caller told her to move it to "a secure holding account".

  3. 039:43 AM

    Every fact opens the record it came from

    Dana Whitcomb · P2P Claims Specialist

    Dana clicks a citation and the passcode log opens with the agent's lines highlighted: the code was texted to her phone ending 0418 to add a new device at 2:16:04 PM, entered on D-7F3A 37 seconds later, and the device added to her profile at 2:17:02 PM. That is what puts payments 1 and 2 on the unauthorized side.

    Read only. Account and phone numbers show their last four digits. Opened by Dana Whitcomb at 9:43 AM, logged.

  4. 049:44 AM

    Confirmed payment by payment, checked against similar claims

    Dana Whitcomb, with the consistency agent

    Dana confirms each placement, and the outcome reads per payment: reimburse $900.00 and $750.00 under Regulation E, reimburse $750.00 under the network's bank impersonation rule, $2,400.00 in all, customer liability $0.00. The consistency agent found 214 similar claims decided in 90 days, 211 the same way, and the recipient ending 6614 in 7 claims from 7 customers in 9 days.

  5. 059:46 AM

    The specialist who drafted it cannot approve it

    Dana Whitcomb

    The sign-off lists exactly what will happen: three reimbursements, recovery request REC-26-018233 for $2,400.00 to Quillon Savings Bank, and the recipient handed to Fraud. Dana sends it, and the screen tells her who approves.

    You confirmed this claim, so you cannot approve it. Luis Ferreira approves.

  6. 069:47 AM

    Approved: credit, ledger, letter and recovery in one move

    Luis Ferreira · Disputes Supervisor

    Luis ticks three checks and approves. The agents credit $2,400.00 to checking ending 2207, post the ledger entries, send the letter by secure message and mail, and file the recovery request with the receiving bank. The letter reads at grade 4.5 and passed 8 of 8 checks.

  7. 07Back in the queue

    The next claim is already placed

    Dana Whitcomb

    Marisol's row now reads "Approved · 9:47 AM". The queue is ordered by the Regulation E clock, and each claim is drawn as a small dividing line, a dot per payment, with hollow dots where the specialist still decides. Overnight the agents read 212 new claims and placed 486 payments; 37 need Dana today.

  8. 08The same day

    Where the money landed goes to the fraud team

    Owen Mbeki · Fraud Analyst

    The recipient ending 6614 is handed to Fraud with its 7 claims and $9,840.00. A Corvane checking account ending 7730, opened online on September 29, received 14 payments from 11 senders in 5 days; Owen can propose a restriction, and the Fraud Operations Manager approves it.

    1 restricted item is hidden for your role

  9. 09Monthly testing

    Same facts, same answer

    Maren Castellanos · Reg E Compliance Officer

    Maren sees each kind of claim with its twins and how they were decided. The 3 bank-impersonation claims that placed new-device payments as authorized were reversed in compliance testing with reason R-3, wrong rule. She draws the monthly testing sample from the same screen.

Who it’s for

Built for everyone who decides a P2P fraud claim.

The same claim, seen by the people who decide, approve, test, chase and audit it: what their day looked like, and what it looks like now.

DW
Dana WhitcombP2P claims specialist · about 45 claims a day, each on a 10-business-day clock
P2P Claims Specialist
Before
Opens four systems for every claim, copies passcode, device and payment records into case notes, then decides the whole claim at once.
Now
Opens a claim with every payment rebuilt and placed, clicks any fact to see its record, and confirms or moves each one with a reason code.
LF
Luis FerreiraDisputes supervisor · approves credits, denials and recovery requests up to $10,000 a claim
Disputes Supervisor
Before
Signs reimbursements and denials from case notes, and the recovery request goes out days later.
Now
Sees exactly what will happen before he approves, and the credit, letter and recovery request go out the minute he does. Never on a claim he worked.
MC
Maren CastellanosReg E compliance officer · tests decided claims every month
Reg E Compliance Officer
Before
Tests a sample for timing and notices, but rarely for consistency, because similar claims are hard to find.
Now
Sees every kind of claim beside its twins, with the decisions that differ listed for her, and draws the sample in one step.
OM
Owen MbekiFraud analyst · money mule investigations
Fraud Analyst, Money Mule Investigations
Before
Hears about the receiving account days after the claim, when the money has moved on.
Now
Receives the receiving accounts and recipients the claims point to the same day, and proposes a restriction for a manager to approve.
CJ
Carla JensenInternal auditor · reads everything, changes nothing
Internal Auditor
Before
Rebuilds who decided, when and on what evidence from several systems before every exam.
Now
Filters one trail of every agent step and human action, and builds a masked export pack for the examiner who asks.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents rebuild each payment, place it on its side of the line and draft the outcome; a specialist confirms, a supervisor approves.

Intake agent

Reads the contact center transcript or the claim form, lists each payment the customer reports, writes her statement in her own words and starts the Regulation E clock from the notice date.

  • Never asks for a police report, an affidavit or contact with the recipient before investigating
  • Never decides
Facts agent

Rebuilds each payment from the passcode and device logs, the network gateway and the core: who started it, on which device, with what authentication, and the recipient's history.

  • Never states a fact without a record
  • Marks a missing record as missing
Classification agent

Places each payment as unauthorized under Regulation E or authorized but induced under the network's imposter-scam rule and the bank's claims policy, citing the rule, its version and a confidence.

  • Never places a payment below the 0.85 confidence threshold; the specialist does
  • Never denies a claim
Consistency agent

Finds decided claims with the same facts and the same recipient, and flags a draft that differs from most of its twins.

  • Never changes a placement; it only flags
Letter agent

Drafts the provisional credit notice, the final letter or the denial at a reading grade under 8, and runs the Regulation E and UDAAP checks on every edit.

  • Never sends a letter
  • Never blames the customer or mentions an internal referral or report
Recovery agent

Drafts the network recovery request, files it with the receiving bank the moment a supervisor approves, tracks the answer and posts recoveries.

  • Never files before approval
  • Never contacts the recipient
Clock agent

Counts ten business days from each notice, skipping weekends and federal holidays, tracks the 45- and 90-day finish and escalates on days 8 and 9.

  • Never extends a deadline
  • Never grants credit itself; it proposes provisional credit for approval on day 10
Disputes Supervisor

Approves every credit, denial and recovery request; never one they worked. The agents propose; a named person decides.

Ask in plain words

Ask about any claim, payment, rule or letter

Ask in plain words, or say what to do. Every answer points to the record it came from, then opens the screen it is about.

Why is the third payment on the induced side?

Payment 3 was started on her own iPhone D-21C9 after a Face ID sign-in from Ohio, and she added the recipient herself at 2:31 PM. She says the caller told her to move it. So it is authorized but induced. The caller posed as Corvane, so the network's bank-impersonation rule and CP-14 § 4.1 reimburse it.

Has the recipient ending 6614 shown up in other claims?

Yes: in 7 claims from 7 Corvane customers in 9 days, $9,840.00 in all, all to Quillon Savings Bank account ending 3390. It is handed to Fraud; Owen Mbeki can propose a block, and Ines Varga approves it.

Which claims run out of Reg E time this week?

86 claims are due in the next 2 business days: 41 tomorrow (day 9, escalated to a supervisor) and 45 on Monday (day 8). The closest is P2P-26-041699, Victor Lindqvist, $2,200.00, due tomorrow.

Draft the denial letter for Tamsin Rourke in plain words

Drafted at reading grade 5.1. It says she sent both $320.00 payments herself to a seller she chose, that nobody posed as a bank or agency, so the rules do not pay them back; that a good-faith recovery request went out; and that she can ask for the documents. Luis Ferreira approves it before it is sent.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Each payment on its side of one dividing lineMarisol Ventura's $2,400.00 P2P fraud claim, on day 1 of its Regulation E clock. Two payments, $1,650.00, sit on the unauthorized side, which Regulation E covers; one, $750.00, sits on the authorized but induced side, which the network's imposter-scam rule and the bank's policy decide. Each payment answers who started it, which device and what authentication, and every answer opens its record.
Every fact opens the record it came fromThe passcode log, with the lines the agent used highlighted: the code was texted to add a new device at 2:16:04 PM, entered on device D-7F3A at 2:16:41 PM and the device added at 2:17:02 PM. Read only, numbers masked to the last four digits, and the opening is logged.
The afternoon rebuilt, minute by minute, in three lanesTwelve events from four systems on one timeline: what the caller said, what happened on her own iPhone, and what happened on the new device. The two payments the caller started sit in the new device's lane; the one she sent herself sits in hers.
The outcome drafted payment by paymentReimburse $900.00 and $750.00 under Regulation E and $750.00 under the bank impersonation rule: $2,400.00 back, customer liability $0.00, a final credit on day 1 with no provisional credit needed. Beside it, 214 similar claims decided in 90 days, 211 the same way, and the same recipient in 7 claims.
The specialist who drafted it cannot approve itThe sign-off lists three reimbursements, recovery request REC-26-018233 for $2,400.00 to the receiving bank and the hand-off to Fraud, then what the agents do on approval. Dana Whitcomb sent it at 9:46 AM; a supervisor who did not work the claim approves.
Approved: credit, ledger, letter and recovery in one moveLuis Ferreira approves at 9:47 AM. The credit posts to checking ending 2207, the ledger entries post, the plain-language letter goes by secure message and mail, and the network recovery request is filed, each step shown as it completes.
Same facts, same answer: twin claims and outliersEach kind of claim with its twins decided in the last 90 days and how they went, from bank impersonation with a passcode read out (214 claims, 99% the same) to purchase scams on the customer's own device. Decisions that differ from their twins are listed for Reg E compliance, who draws the monthly testing sample here.
Where the money landed goes to the fraud teamReceiving accounts and recipients the claims point to, handed to Fraud the same day: J. Collier, 7 claims from 7 customers in 9 days, $9,840.00, and a Corvane account that took 14 payments from 11 senders in 5 days. A restriction needs a fraud analyst to propose it and the Fraud Operations Manager to approve it.
A denial that explains why, checked before it can goFor a purchase scam the rules do not cover, the letter says why in plain words and offers the documents relied on, under 12 CFR 1005.11(d). The Regulation E and UDAAP checks run on every edit: add a blame phrase and the letter cannot be sent until it is fixed.
Below the confidence threshold, the specialist decidesJordan Pike says he did not send two payments, but both started on his own phone with Face ID, to a recipient he has paid 12 times. At 0.71, below the 0.85 threshold, the payments stay on the line for the specialist to place with a reason code.
The queue, drawn as small dividing lines1,214 open claims ordered by the Regulation E clock, each drawn as a miniature line with a dot per payment and hollow dots where the specialist still decides. Overnight the agents read 212 new claims and placed 486 payments; 37 need the specialist today.
Regulation E clocks, counted in business days86 claims due in the next 2 business days, with weekends and federal holidays skipped. The specialist is reminded on day 8, the supervisor takes escalations on day 9, provisional credit is proposed for approval on day 10, and a deadline is never extended by an agent or a person.
An audit trail and an export pack for examinersA pack for CFPB examiners for October 1–22: 1,554 decided claims with 4,212 records and 1,554 approvals, account and phone numbers masked, and restricted referrals left out, because they go only in a pack for the BSA officer.
Governance

Built for P2P fraud claim risk: cited, approved, on the record.

Eight roles, separated by dutyA claims specialist confirms and drafts; a disputes supervisor approves up to $10,000 a claim; the Head of Disputes approves above that, goodwill and settings; Reg E compliance tests; a fraud analyst proposes restrictions and a fraud operations manager approves them; an internal auditor reads and exports; an administrator proposes settings and works no claims.
Maker and checker on every money moveEvery reimbursement, denial, provisional credit and recovery request is approved by a supervisor who did not work the claim, and every account restriction by the Fraud Operations Manager. The person who confirmed a claim cannot approve it.
Every fact cites its record, every rule its versionA specialist can click any fact and open the passcode log, the device record or the transcript at the line the agent used. Each placement names its rule: 12 CFR 1005.2(m) and the CFPB's FAQs, or the network rule version 2025.2 and claims policy CP-14 version 7.
Below the threshold, a person places the paymentUnder 0.85 confidence the agents place nothing, and the specialist chooses a side with a reason code. Any placement can be moved across the line with a reason code; that override is on and cannot be switched off.
No tipping off, masked by defaultA BSA referral is visible to Fraud and the BSA officer only, never on a letter, a customer view or a non-BSA export. Account, card and phone numbers show their last four digits; transcripts open only from a claim, and every opening is logged.
A full trail and an export pack per examinerWho, what, when, why and which evidence, for every agent step and human action. The export pack is built for the CFPB, OCC, FDIC, Federal Reserve, a state examiner, internal audit or the BSA officer, masked, with restricted referrals only in the BSA officer's.
Configuration

Your claims policy, not ours

The rules every claim is placed against are settings with versions. The administrator proposes a change, and the Head of Disputes approves it before it is in force.

SettingDefaultChoose from
Placement confidence threshold0.850.80, 0.85 or 0.90; below it the specialist decides
P2P network rule setVersion 2025.2Imposter-scam reimbursement, effective June 30, 2023
Claims policyCP-14, version 7Zero liability § 2.1, bank impersonation § 4.1, purchase scams § 4.3, customers 75 or older § 4.4
Twin-claims outlier80% of twinsA draft that differs from this share of its twins needs a reason code
Approval limits$10,000 a claimSupervisor alone up to it; Head of Disputes above, and every goodwill exception
EscalationDays 8, 9 and 10Specialist on day 8, supervisor on day 9, provisional credit proposed for approval on day 10
LettersWithin 3 business days of a decisionSecure message and mail; credit, provisional credit and denial templates
Retention5 yearsBSA, 31 CFR 1010.430; longer than Regulation E's 2 years, 12 CFR 1005.13
Connections

Works with the systems a disputes team already runs on

P2P network gatewaypayment records, recipient tokens and recovery requests
Digital banking platformauthentication, passcode and device logs
Core banking systemaccounts, balances and credits
Contact center transcriptscalls and chat, by customer
Case managementfraud and BSA referrals
General ledgerloss, reimbursement and recovery entries
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
Day 1of 10
the claim decided on day one of the Regulation E clock, with the recovery request filed the same hour
Decided on day 1
10 business days allowed
target
100%
of placements cite the record that puts them there and are checked against similar decided claims
Decided per claim, by handuneven
Per payment, citedevery one
typical
38%
of reported P2P fraud repaid by the network's three largest owner banks in 2023, down from 62% in 2019

“demo” = seen in the working solution, on its sample data · “target” = the design goal, to be measured in the live solution · “estimated” = our estimate · “typical” = published figures (US Senate Permanent Subcommittee on Investigations, staff report on P2P fraud reimbursement, July 2024: the network's three largest owner banks repaid 38% of reported P2P fraud in 2023, 62% in 2019, and 12% of scam claims). Rules named: Regulation E, 12 CFR 1005.2(m), 1005.11 and 1005.13; CFPB Electronic Fund Transfers FAQs (Unauthorized EFTs, Question 5, June 4, 2021; Error Resolution, Question 4); 31 CFR 1010.430 and 1020.320(e). Corvane National Bank, Quillon Savings Bank and the people, devices, accounts and numbers named on this page are fictional: characters and sample data in the working solution.

Questions

What disputes teams ask about P2P fraud claims.

What is P2P Fraud Claims?

P2P Fraud Claims is software for dispute teams that resolve P2P fraud and scam claims, separating unauthorized from induced payments. Seven agents rebuild each payment in a claim, place it as unauthorized under Regulation E or authorized but induced under the network's imposter-scam rule and the bank's policy, and draft the outcome, the letter and the recovery request. A claims specialist confirms each placement and a supervisor approves.

What is P2P fraud?

P2P fraud is money lost through a person-to-person payment service, either because a fraudster sent the payment from the customer's account or because a scammer talked the customer into sending it. The two are treated differently: the first is an unauthorized transfer under Regulation E, and the second is authorized but induced, decided by the network's rule and the bank's policy. One claim often holds both kinds.

Is a P2P payment covered by Regulation E if the customer shared the passcode?

Under the CFPB's Electronic Fund Transfers FAQs (Unauthorized EFTs, Question 5), a transfer started by a third party who tricked the customer into sharing access information is unauthorized. In the working solution, two payments made from a device added with a passcode the customer read to a caller are placed on the unauthorized side, citing 12 CFR 1005.2(m) and that FAQ.

Are imposter scams reimbursed when the customer sent the money herself?

Not under Regulation E, but the P2P network's imposter-scam rule has required reimbursement for qualifying bank, government and network impersonation scams since June 30, 2023, and a bank's own policy may go further. The classification agent places such a payment on the induced side and cites the rule version and the policy section, such as CP-14 § 4.1 for bank impersonation; a purchase scam the rules do not cover is drafted as a denial for a supervisor to approve.

How does it keep the Regulation E dispute timeline?

The clock agent counts 10 business days from the notice, 20 for accounts open 30 days or less, and the 45- or 90-day finish, skipping weekends and federal holidays. It reminds the specialist on day 8, escalates to a supervisor on day 9 and proposes provisional credit for approval on day 10. It never extends a deadline.

Does it ask the customer for a police report?

No. The CFPB's FAQs (Error Resolution, Question 4) say a bank may not delay an investigation waiting for a police report. The intake agent never asks for one, and the letter checks block any such demand.

Do people stay in control of each decision?

Yes. The specialist confirms or moves every placement with a reason code, and below the 0.85 confidence threshold the agents place nothing. A supervisor who did not work the claim approves every reimbursement, denial, provisional credit and recovery request; the agents never approve, deny or send on their own.

How does P2P Fraud Claims go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your claims policy, letter templates and a sample of past claims, and it goes live once every quality gate has passed. We will walk you through it on your own claims first.

See it on
your P2P fraud claims.

We'll run P2P Fraud Claims on a sample of your own past P2P fraud and scam claims.