If necessary, the bank can require the ODFI to require that the Originator produce evidence of the authorization. If, however, the customer's claim is too late to use the NACHA reversal (for example if the customer today, on August 2, 2010, claims that four ACH entries from 2009 were not authorized), the RDFI still has to comply with Reg E under section 205.6, whether or not the bank can use the NACHA returns process to recover funds. ![]() The RDFI's Reg E claims log would reflect that the claim was resolved by using the ACH returns process. Because the Originator can't counter the claim, the matter becomes one between the Originator and the Receiver/consumer, with the bank out of the picture. One way in which most banks exceed the standard is (when the consumer customer makes the claim promptly enough) simply accept the WSUD (fka WSUPP) and immediately close the case, credit the customer and enter the adjustment reversal transaction to recover the funds. You are always free to exceed that standard. Regulation E sets the minimum standard for addressing claims under section 205.11. #1422830 - 08/02/10 06:21 PM Re: Reg E & ACH Rules - Revoked Authorization cjdod Thanks for any further info on a complex issue. I just don't understand what we are required to do under Reg E, should we just have a log for the ACH disputes with notations that it was resolved under ACH rules, would that make everyone happy. Under these rules could the customer refuse to sign the WSUPP and under Reg E we would have to credit the customer? We would have to contact the Originator via the ODFI and demand a copy of the signed authorization form in order to determine if the transaction was authorized but even if such a form is provided, the customer is claiming they revoked authorization, the bank or Originator will probably not admit to having a revoking authorization letter from our customer and it turns into a he said she said scenario which is why we have the WSUPP.Īs long as we credit the customer does it matter how the claim is processed? In my opinion, if it weren't for the ACH rules and the WSUPP, most banks would have to credit the customer under Reg E and the bank would would have a loss unless the ODFI failed to provide a siged authorization form from the originator. In the case of an ACH how is the bank supposed to determine if an ACH was authorized and if it was authorized but authorization was revoked, there is actually no way to prove this. We keep the WSUPPs on file in case there is a dispute with the return. ![]() I am skipping some timing requirements but that is generally how we handle these claims. When ever a consumer makes such a claim, we would just have them complete a WSUPP, we credti their account and return the ACH item. Are all unauthorized ACH transaction (consumer) claims, Reg E claims and do they have to be treated just like other Reg E claims? I was reading your post about Reg E and unauthorized ACH and I am a little confused.
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