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#1996579 - 02/18/15 03:53 PM NACHA OR7 2.3.2.5(b)
MMONACO Offline
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Joined: Aug 2007
Posts: 5
We allow consumers to originate ACH transactions to external accounts after they have verified two micro-deposits. If an RDFI requests a copy of Receivers authorization, what are we the ODFI required to supply?
Currently, our consumers simply verify the micro-deposits? Any advise is greatly appreciated.

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eBanking / Technology
#1996594 - 02/18/15 04:17 PM Re: NACHA OR7 2.3.2.5(b) MMONACO
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
See OR 2.3.2.1

No authorization by the Receiver is required in the case of credit entries for which both the Originator and the Receiver are natural persons. And as ODFI you make no warranty with respect to the authorization.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1996696 - 02/18/15 08:01 PM Re: NACHA OR7 2.3.2.5(b) MMONACO
MMONACO Offline
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Joined: Aug 2007
Posts: 5
Sorry I should have mentioned that once the mirco-deposits are verified, we allow our consumers to originate debits and credits.

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#1996698 - 02/18/15 08:14 PM Re: NACHA OR7 2.3.2.5(b) MMONACO
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
OK. So I've signed up and you've approved me and I hold an account in another institution. I decide I need to move money from the other bank to my account with you, so I originate an outbound ACH debit to that other account for, say, $500.

The RDFI asks you for documentation of the authorization. You show them a log extract showing that John Burnett issued a debit to (demonstrably) his own account at the other bank. Since the accounts are both owned by the same individual, the Receiver has authorized the transaction (per the log extract).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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