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#465925 - 12/05/05 09:02 PM Reg E and ACH Prenotes
Shopgirl Offline
Diamond Poster
Joined: Aug 2003
Posts: 1,264
Southeast
If a customer indicates that the Pre-Note to an ACH transaction is not correct and wants it stopped, should we track these situations as we do our normal Reg E unauthorized transactions?

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eBanking / Technology
#465926 - 12/05/05 10:05 PM Re: Reg E and ACH Prenotes
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A prenote isn't subject to Regulation E at all because it's not a transaction to or from the consumer's account. That said, you should heed your customer's request that transactions from the Originator not be posted. I suggest you get a statement in writing from your customer that the transactions aren't to post. Then prepare to return each of the dollar transactions as unauthorized.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#465927 - 12/05/05 10:08 PM Re: Reg E and ACH Prenotes
Shopgirl Offline
Diamond Poster
Joined: Aug 2003
Posts: 1,264
Southeast
Thanks John, since the time I posted I had a little while to think about it, and concluded as you said.....prenote not subject to Reg E. But again, thank you for your confirmation.

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