Assuming that we (as the financial institution) originated this as a loan payment. As the ODFI, would the customer have any claim if we reversed an old payment (over a year ago) that was made and is now claimed as unauthorized? The payment in question was made from the account of the customer's ex, not of the customer.
I would prefer to kick it back, but I was asked by management if we would have any liability if we allowed the late return post. I haven't found any reference yet, but I was hoping I would so they'll let me return it.
Agreed. You have a deposit contract with your customer. You have no such contract with the other end of this mess (the ex). Since NACHA rules don't permit a late return using the ACH, you should let sleeping dogs lie.
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8