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#1531306 - 04/04/11 08:30 PM Point of Sale and ACH Reg E Disputes
Too Young To Retire Offline
Member
Joined: Jun 2005
Posts: 97
Getting ready to work on an error resolution compliance review. Confused about ACH. I know investigations for ATM disputes has to be completed withing 45 days. POS is within 90 days. Is ACH considered POS and have 90 days or does it have 45 days? Does it make a difference whether they used their debit card to initiate the ACH or gave their checking account number? Thanks for any help to make this clearer!
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Operations Compliance
#1531323 - 04/04/11 08:59 PM Re: Point of Sale and ACH Reg E Disputes Too Young To Retire
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,365
Illinois
ACH is not considered point of sale and would fall under the 45-day schedule.

Also, a debit card charge can only hit a checking account as a point of sale or ATM withdrawal. That being said, some merchants such as Target are now offering a product known as a "decoupled debit card." The customer gives the merchant their checking account number and purchases on that card are presented as ACH. If the customer wishes to dispute a decoupled debit card purchase they would contact the card issuer, which in that case, is not the bank.

If they completed a written statement of unauthorized debit on an ACH for one of these transactions, the card issuer could come back to you and show that the customer authorized them to make ACH withdrawals for purchases on that card.
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#1531614 - 04/05/11 05:57 PM Re: Point of Sale and ACH Reg E Disputes BrianC
Too Young To Retire Offline
Member
Joined: Jun 2005
Posts: 97
So I just want to make sure I'm understanding. If I give my debit card number out over the phone or on the internet to purchase something that's considered a POS? But if I give my checking account number out in either of those instances it's considered an ACH?
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#1531675 - 04/05/11 06:54 PM Re: Point of Sale and ACH Reg E Disputes Too Young To Retire
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,365
Illinois
That is correct. I do not know how your core system identifies the transactions. Ours uses a seperate transaction code for debit card purchase and ACH withdrawals so it is very easy for us to distinguish.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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