Course description

Bank customers’ payment patterns are changing. Transactions by check are declining, while those completed by debit card and ACH continue to rise. Nacha has been particularly successful in its efforts to grow its piece of the payments marketplace. Nacha reported there were 31.5 billion ACH payments valued at $80.1 trillion in 2023, an increase of 4.8 percent over 2022 volume and 4.4 percent over 2022 in payment value. With that volume comes an increase in unauthorized transactions, making accurate and timely management of unauthorized transaction claims increasingly important for your bank.

For many of those claims – those made by consumers – Regulation E prescribes a claims investigation and management process. There are specific timing, notification and resolution requirements, along with the potential for provisional credit to the consumer while your investigation proceeds. There are also precise requirements on allocation of liability to the consumer for unauthorized EFT claims involving a series of transactions over multiple months. Those Regulation E rules co-exist with Nacha rules that can seem to conflict with Regulation E.

Nacha’s rules affect claims involving consumer accounts and claims involving business accounts differently. Different return deadlines can apply, and different authorization warranty periods can affect your ability to collect on older ACH debits that your customer claims were not authorized.

Sorting out which rules apply to specific scenarios so that your bank handles a claim with procedures that are both timely and compliant can be a challenge – and mistakes in policy, procedures or practice in handling claims of unauthorized transactions can result in poor customer service and increase the risk of regulatory criticism, adverse public relations and losses through litigation.

This webinar analyzes Nacha rules and Regulation E to give your bank the information needed to develop compliant procedures to mitigate those risks.

During the presentation, we’ll carefully review –

  • Authorization requirements under Regulation E and Nacha Rules
  • What you can require a consumer to provide with a claim that an ACH entry was unauthorized
  • Processing oral claims
  • The Regulation E error claims process
  • Timing requirements for a customer’s claim under Regulation E and under Nacha rules
  • Nacha’s return restrictions, by transaction and customer type
  • Using the right ACH return reason code
  • The subtle differences between the R10 and R11 return codes
  • The WSUD and when it is required
  • How Regulation E’s lack of an unauthorized EFT “statute of limitations” affects claims handling
  • When it’s too late for a return -- Claims under Nacha’s revised authorization warranty
  • The impact of unauthorized ACH entries on the ODFI
  • and more …

This webinar addresses only unauthorized ACH entries. Debit card transactions are not discussed.

 

Instructor(s)

John Burnett

John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the BankersOnline.com team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.

Course curriculum

  • 1

    Webinar

    • Access Webinar

  • 2

    Materials

    • Materials

    • Slides

Reviews