If the customer wants to sign a WSUD that says they never authorized the debits, you can return the ACHs within the last 60 days. If appropriate, you can also contact the ODFI and request a copy of the authorization.
Another question is, how many debits have come in? Do they exceed the amount of the credit? Reg E places some liability on you, but the customer can not profit from the error. Since you know the debits are payments for the credit, they are all part of the same error. You should also look into the Reg E liability timeframes. It is hard to say exactly what course of action you should take without a lot more details, but a good place to start would be the BOL Reg E Calculator:
http://www.bankersonline.com/tools/compliance/regecalc_liabcalctool.htmlMake sure you follow the Reg E investigation time frames, but don't finalize any provisional credit you may give the customer until your investigation is complete or your
90 45 days is up.