In short, if the transaction hits your bank as a debit card transaction, your bank is responsible for EFT error claim processing and unauthorized transaction management under sections 1005.11 and 1005.6, respectively.
But if the transaction hits the bank as an ACH debit where the P2P or other fintech uses the consumer's check bank routing number and account number to originate an ACH debit to complete the P2P payment/transfer, you don't have an agreement with the fintech, and the fintech will be subject to 1005.14.
Last edited by John Burnett; 01/18/23 08:08 PM. Reason: typo
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8