Reg E, ACH, Visa Error Resolution Rules
by John Burnett, BOL Guru Guru BIOS
Question: Are there different ACH and/or VISA rules for error resolution, or do the timelines and requirements of Reg E apply?
Answer: Regulation E error resolution rules apply to all EFT transactions in consumer accounts. Period.
There are no error resolution rules, per se, for the ACH. NACHA rules do impose a deadline for returning consumer ACH entries that may be the focus of Reg. E error resolution processes, and that deadline is between 1 and 30 days shorter than the cutoff for customer liability for unauthorized transfers under Reg. E. Accordingly, the receiving bank may find itself holding a transaction or two that it had to recredit to its customer but cannot return via the ACH.
However, the ACH still has warranty rules that make an Originator accountable for unauthorized transfers. Although warranty claims cannot be made via the ACH structure, they can be pursued in state and federal courts.
Visa rules impose a shorter provisional recredit deadline (5 days) and liability ceiling ($0, with exceptions) on SOME Visa transactions.
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