Contact your bank or credit union immediately. Tell it you are disputing a specific transfer as unauthorized, give the date, amount and recipient if you know them, and ask it to secure your account and investigate. If the transfer is pending, ask whether it can be stopped; if it was a bank wire, ask right away whether the bank can recall or reverse it. Recovery is not guaranteed.
There is no special federal rule for transfers made by an AI agent. Whether a transaction is legally unauthorized depends on the account, payment method, how the agent obtained access, what authority you gave it and the other facts. Regulation E may apply to certain transfers from consumer accounts, but it does not automatically cover every account or payment rail.
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What should I do first?
- Call the bank or credit union through an official channel. Use the number on your card or statement, or the institution’s official app or website. Identify the transaction and state plainly that you dispute it as unauthorized. Ask the representative to open an investigation, secure the account and tell you whether a pending transfer can be stopped. For a wire, ask immediately about a recall or reversal.
- Get the case details in writing. Record the date and time of your contact, the representative’s name if available, and the case or confirmation number. Ask what written confirmation the institution requires and where to send it. If you first report by phone, Regulation E permits a financial institution to require written confirmation within 10 business days; it must begin investigating promptly and cannot wait for that confirmation to start.
- Cut off further access. Ask the institution how to block or replace exposed credentials and prevent additional transfers. Change relevant banking credentials through the official app or website, revoke the agent’s access, and review connected services or permissions. Where feasible, save the agent’s instructions, permissions, logs and activity before deleting or changing its configuration.
- Check the account for related activity. Review recent transactions and statements, and report other transfers you do not recognize promptly. Keep copies of statements, messages with the bank, and any records showing what the agent was permitted to do.
- Follow the investigation through to a written result. Ask how to submit supporting records and how to request the information the bank used to make its decision. Keep the bank’s response and any provisional credit notice.
Does Regulation E treat an AI agent’s transfer as unauthorized?
Regulation E defines an “unauthorized electronic fund transfer” as a transfer from a consumer’s account “initiated by a person other than the consumer without actual authority to initiate the transfer and from which the consumer receives no benefit” (12 CFR § 1005.2(m)). Those elements matter: who initiated the transfer, whether that person had actual authority, and whether the consumer benefited.
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The definition alone does not decide whether an AI agent acted with authority. The CFPB’s published guidance does not establish a specific AI-agent rule or settle how a particular grant of access, spending limit or instruction applies. Explain the arrangement accurately to the bank: whether you enabled the agent, what account access you gave it, what actions you allowed, and how the transfer differed from those permissions. Save records that support your account of events.
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Regulation E also excludes certain transfers by someone to whom the consumer furnished an access device and gave authority to make transfers, unless the consumer told the financial institution that the person was no longer authorized. The effect of deliberately giving an AI agent access is not directly resolved by the official guidance discussed here. Do not assume either that any transfer by an enabled agent is authorized or that a transfer outside your intended purpose automatically qualifies as unauthorized under the rule.
The CFPB says a transfer initiated by a fraudster who obtained account credentials through a data breach or fraudulent inducement may qualify as an unauthorized EFT. It also says a qualifying fraudster-initiated person-to-person credit-push transfer may qualify, and that the bank must begin investigating after notice rather than requiring the consumer to contact a merchant first. That guidance may be relevant if an intruder took over the agent or account; it does not determine whether an agent you deliberately enabled had authority.
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Which rules and recovery steps depend on the transfer?
| Situation | What to do or consider |
|---|---|
| Consumer account and covered electronic fund transfer | Regulation E’s error-resolution and liability provisions may apply. Report the transaction to the institution and ask it to investigate. |
| Business account | The consumer-account protections described here may not apply. Check the account agreement and ask the institution which procedures and deadlines govern the dispute. |
| Bank EFT or qualifying P2P transfer | Ask the institution to treat the transaction as a disputed unauthorized transfer and investigate. The CFPB’s guidance recognizes that some fraudster-initiated P2P credit-push transfers can qualify as unauthorized EFTs. |
| Bank wire | Contact the bank immediately and ask whether it can recall or reverse the wire. The FTC recommends asking, but does not promise the money can be recovered. Do not assume a wire receives the same treatment as a covered Regulation E EFT. |
| Agent had access or was given authority | The actual permissions, instructions, access method and circumstances may affect whether the transfer was unauthorized. Preserve and provide the relevant records; official guidance does not resolve every AI-agent arrangement. |
| Credentials were stolen or an intruder took control | Tell the bank how access was obtained and provide any evidence of compromise. CFPB guidance describes circumstances in which a fraudster-initiated EFT may be unauthorized. |
| Transfer is pending | Ask the institution immediately whether it can stop it. Whether a stop is possible depends on the transaction and its status. |
| Transfer is complete | Still report it promptly and ask the institution to investigate; a completed transfer is not, by itself, a guarantee that recovery is impossible or that it will be granted. |
What reporting deadlines matter for a consumer EFT?
Regulation E’s liability rules depend on the facts, including whether a lost or stolen access device was involved. The periods below are regulatory timing rules, not promises that a bank will reimburse a particular transfer.
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|---|---|
| Within two business days after learning that an access device was lost or stolen | For an unauthorized EFT involving that lost or stolen device, liability is generally limited to the lesser of $50 or the amount transferred before the institution received notice. |
| After the two-business-day period | Under specified conditions, liability may be as much as $500 plus certain unauthorized transfers made after the two days and before notice. The rule’s conditions matter; the amount is not an automatic charge. |
| Within 60 days after the institution sends a statement showing an unauthorized EFT | Reporting within this period helps avoid potential liability for later transfers that the institution establishes would not have occurred if it had received timely notice. |
| More than 60 days after the statement was sent | You may be liable for certain later transfers that timely notice would have prevented, as established by the institution. Report the problem as soon as you discover it. |
The two-business-day liability tiers concern a lost or stolen access device. If no access device was involved, those first tiers do not apply in the same way. Because the applicable result is fact-specific, ask the bank to explain how it is applying the rule to your transaction.
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How long can the bank take to investigate?
For a covered Regulation E EFT dispute, the institution generally must investigate promptly and determine whether an error occurred within 10 business days after receiving notice. If it needs more time, it can generally take up to 45 days if it provides provisional credit within 10 business days, subject to exceptions, including certain transaction types and cases where required written confirmation is not provided. Provisional credit is conditional; it is not a final decision that the bank must reimburse you.
After completing the investigation, the institution generally must tell you the result within three business days. If it determines an error occurred, it generally must correct it within one business day. You may request copies of the information the institution relied on in making its decision. Ask the bank which timing rules it believes apply to your transaction and note the dates it gives you.
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What should I give the bank?
- Transaction date, amount, recipient and any transaction or confirmation number.
- A clear description of how the agent could access the account and the actions you authorized or prohibited.
- Relevant agent instructions, permissions, activity logs, alerts and communications, if available.
- Evidence of a lost device, credential exposure, account takeover or other suspected compromise.
- Your record of when you discovered the transfer and when you notified the institution.
Keep the original records where possible and send copies through a channel the institution identifies. Do not delete potentially relevant agent or account records simply to disable access; preserve what you can while following the bank’s security instructions.
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