Sticky ACH Situations

With Rayleen Pirnie

Sticky ACH Situations

With Rayleen Pirnie
  • 1 Video
  • 2 PDFs
  • 2.0 hrs
Course description

ICB Credit: 2.5 CRCM

Handling consumer disputes of ACH debits is something community bank retail centers and call centers are often faced with. Many situations are not covered in the ACH Rules book and there is often no clear direction from other resources. This session focuses on the most common disputes, and provides frontline staff with a basic understanding of what is required to maintain compliance. Plus, we'll provides tips on handling these disputes. The course concludes with some real-life "sticky situations" where attendees try their hand at solving the issue while balancing compliance obligations with customer service.

This program would be ideal for someone new to these situations and would be an excellent refresher for those who have a few ACH battle wounds.

Learning Objectives

By attending this program, you will be able to:

  • Understand common consumer ACH disputes, including areas where Regulation E and the ACH Rules don't agree
  • Document your institution's obligations and rights
  • Realize how what you say or do can impact the situation
  • Decide the appropriate course of action in given situations


  • Regulation E doesn't always align with the ACH Rules
    • Who each is written for
    • Regulation E "Notice" requirements vs. ACH Rules return requirements
    • What to do when a customer/member won't complete a WSUD
  • State laws
    • 60 day in-network returns vs. state statute of limitations
    • State consumer protection laws (high level - no specific states covered)
  • Sticky Situations
    • "I want a stop payment" but the item has already posted
    • "I already revoked authorization with them"
    • "I never authorized that" / "That's fraud!"
    • "I only owed them $23, not $25 - I want my $2 back."
    • "I was charged $40 last month for my gym membership, but now they are saying they never got the money." (TPS issues)
    • "I don't know who this company is or why they debited my account."
    • "I wrote a check for $35 - it cleared and so has this $35 electronic debit."
    • "My ex stole my part of the tax refund. I want my half."
    • "I was scammed!"
  • What NOT to say to a consumer, ever
  • Documenting and reporting claims
  • Case studies exercise - attendees try to resolve, then we discuss
    • Online dating scam
    • Payday loans
    • Tax refund fraud
    • Magazine subscription - been debiting the account for 2 years

Who Should Attend:
This informative session is designed for frontline personnel, as well as anyone in the institution responsible for managing ACH disputes, particularly Branch Managers, Risk Managers, Compliance, Audit, Retail Managers, Trainers, and Senior Management.

Course Curriculum

Sticky ACH Situations
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Sample Stop Payment Order to Your Bank
Sample Notice of Unauthorized Transfer
Case Study
ODFI Liability Breach of Warranty
Questions and Answers
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Rayleen Pirnie
Rayleen Pirnie

Rayleen is the founder and owner of RP Payments Risk Consulting Services, LLC. based in Missouri. She is a nationally recognized payments risk and fraud expert. Her programs educate financial institutions and businesses on topics ranging from payments fraud to information security. She is the author of several payments risk and fraud blogs geared toward helping organizations recognize threats and protect themselves from loss.

Always interested in Risk Management, Rayleen has supported many notable organizations over the years. She is a member of the International Association of Financial Crimes Investigators, supporting their training programs since 1998. She sat on NACHA’s Risk Management Advisory group for two terms, and assisted with FSISAC’s first CAPP exercise.

For 16 years Rayleen has spoken at national and regional conferences. Recent events include NACHAs Payments Conference, the American Bankers Association Risk Management Forum, the Security Matters annual conference at Murray State University, the Risk Management Association, and the Federal Reserve Bank of Kansas City Risk Management Conference.