I just want to make sure my read of the OR/OG is correct--

Is a Web Credit appropriate for ALL transactions where both sides of the transaction are a natural person, or just those initiated through the internet or mobile networks? My read of the rules is Web credit can be used on any P2P transaction (even non-www) as web credit requires no authorization from the receiver.

Conversely, is a WEB debit appropriate for ALL P2P transactions, or just those initiated through the internet or mobile networks? My read of the 2015 rules still indicates WEB debit is only appropriate when authorized through the internet.

Our Core pushed out a programming change, and as of the programming change, ALL ACH transactions that credit an external account where both our account owner and the external account owner are person results in a WEB debit to the in-house account, and a WEB credit the external account. This is both for one-time and recurring transactions.

I think the use of WEB debit here is inappropriate unless the transfer was initiated online. There's no way to change this because our Core does not allow for choosing the SEC. The SEC is assigned based on the context of the transaction.
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Nothing I say should be considered legal advice or the opinion of my employer.