I'll let M&M provide the definitive answer to your question, Titanic. However, I can hazard a guess. Enlisting a customer's cooperation in getting ACH funds back can be a delicate balancing act. Some banks take a decidedly rigid stance -- We need the WSUPP before we can pursue your refund, Customer. Others take a more liberal stance -- We'll give you back your money, Customer, right away, and we'll worry about the paperwork later. Regulation E suggests that the liberal approach is appropriate; bottom-line watchers are in favor of the rigid approach, which may bend and ignore Reg. E occasionally.
Somewhere in the middle is the institution that complies with the Regulation, but finesses its communication with the customer in such a way as to encourage cooperation in getting the WSUPP completed.
"We're happy to look into this transaction, Customer, and get you back your money quickly. We'd like your help in getting our money back from the people who charged your account. Can you sign a statement that says the transaction was unauthorized, please? We can have it ready for you at our __________ office. Better yet, if you have a fax number, we can get the form to you so you could sign it and fax it right back to us. If we get the signed form back quickly, we can move ahead on getting those funds back right away."
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8