Bank customers’ payment patterns are changing. Transactions by check are declining, while those completed by debit card and ACH continue to rise. NACHA, The Electronic Payments Association, has been particularly successful In its efforts to grow its piece of the payments marketplace. In July 2019, NACHA touted a jump of 46% in its quarterly Same Day ACH volume over the prior year, with almost 60 million same-day credits and debits processed in the second quarter of 2019. Overall second quarter ACH volume included more than 3.55 billion debits and 2.55 billion credits. With that volume comes an increase in unauthorized transactions, making accurate and timely management of unauthorized transaction claims more and more 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.
Sorting out which rules apply to specific scenarios so that your bank handles claims with procedures that are both timely and compliant can be more than 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 WSUD and when it’s 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 ongoing 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.
Questions and Answers
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