I tend to take a conservative view on this (read: pro-consumer, since that's the bent of the EFTA and Reg E), and treat the ACH transactions and the debit card transactions as two separate fraud cases, regardless of how they might be reported by the consumer. I don't see, for instance, how the prompt reporting of the ACH fraud entries would have prevented the debit card problem.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8