What are other FIs doing regarding the new ACH WSUD? The issue I have is permanently blocking future payments when the customer advises you that they have revoked their authorization with an Originator. You cannot return an entry “R07-Authorization Revoked” without a WSUD, which under the new rules cannot be completed until after a transaction posts. This change seems contrary to the Reg E Official Staff Interpretation, Section 205.10(c)2:
“Once a financial institution has been notified that the consumer’s authorization is no longer valid, it must block all future payments for the particular debit transmitted by the designated payee-originator...The institution may not wait for the payee-originator to terminate the automatic debits.”
Under the old rules, there was no timeframe for completing a WSUPP, so we revised the wording to cover future transactions. That's no longer possible.
I went to a seminar by our regional ACH payment association on the new changes, and they suggested educating the consumer on their responsibility to contact the Originator to revoke their authorization, and the Originator will stop the entries according to NACHA rules. (That might work in a perfect ACH world, but experience tells me otherwise.) The second option they suggested is obtaining a stop payment, but returning an entry "R08" does not convey the Receiver's intent to permanently revoke it, so Originators can keep on originating entries...
Some of the other FIs in attendance said they were going to have their customers pre-sign an undated WSUD. That just doesn't sit well with me...
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Let's start at the very beginning; A very good place to start...