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#2198359 - 11/15/18 08:14 PM Fee for unauthorized entry ?
Anonymous
Unregistered

Do others charge a fee to customers when an operational stop pay is placed on the system after return of an unauthorized ACH entry ? Wouldn't this seem to be contrary to Regulation E and possible violation for not making the customer whole ? Input is appreciated.

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#2198373 - 11/15/18 08:56 PM Re: Fee for unauthorized entry ? Anonymous
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,712
Illinois
The commentary to 1005.11(c) tells you why this is not an acceptable practice.

3. Charges for error resolution. If a billing error occurred, whether as alleged or in a different amount or manner, the financial institution may not impose a charge related to any aspect of the error-resolution process (including charges for documentation or investigation). Since the Act grants the consumer error-resolution rights, the institution should avoid any chilling effect on the good-faith assertion of errors that might result if charges are assessed when no billing error has occurred.
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#2198376 - 11/15/18 09:03 PM Re: Fee for unauthorized entry ? Anonymous
kiemo Offline
Gold Star
kiemo
Joined: Jan 2009
Posts: 267
MidUS
Thank you for the directive BrianC!

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