If a customer calls questioning why his direct Social Security deposit wasn't made this month, and it has been in previous months, what is the correct procedure. Does the bank need to log in the call as an error and help the customer resolve the error, or can the bank refer the customer back to Social Security?

Another scenario is if a customer calls saying that his direct deposit payroll from his employer is not for the correct amount. Can the bank refer the customer back to the employer, or does the bank have to log the call in as an error, and research it, then refer the customer to the employer if there is no error by the bank?

What are the proper procedures to ensure compliance with Reg E?

In both cases, the customer is protected by §205.11. Nonreceipt of the SSA payment is under §205.11(a)(1)(iii) and the incorrect pay deposit is under §205.11(a)(1)(ii). In each case, there is no privity of contract with the originator. Therefore, the bank's research requirement stops at its door.

In other words, you must process the resolution request by researching the data you received from the ACH. Once you've done that, you tell the customer that the transaction was correctly processed by the bank (payroll) or not received by the bank (SSA). At that point, you've completed your work. It's up to the customer to pursue the problem with the originator.

Even though you know in advance the outcome of the research for each of these scenarios, you must process the request before informing the customer of your intent to make no adjustment. There's always that slight chance that you'll find an unposted SSA credit or a reversal and new credit for the payroll deposit.