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#1706650 - 06/05/12 03:19 PM ACH - CCD Debit Transactions Disclosure
Wishful Thinker Offline
Member
Joined: Dec 2008
Posts: 77
Could anyone tell me if it is required to disclose in a Deposit Account Agreement the limitations on ACH CCD debit transactions? Have been researching and I see it on some deposit agreements, but not all I have looked at has it mentioned in their disclosure.

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#1706708 - 06/05/12 04:02 PM Re: ACH - CCD Debit Transactions Disclosure Wishful Thinker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
What limitations? What type of accounts?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1706722 - 06/05/12 04:09 PM Re: ACH - CCD Debit Transactions Disclosure rlcarey
Wishful Thinker Offline
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Joined: Dec 2008
Posts: 77
The fact that if returning a corporate debit transaction (CCD) via ACH, it must be returned within 24 hours of posting. Does this have to be disclosed in the deposit account agreement given at account opening.

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#1706728 - 06/05/12 04:13 PM Re: ACH - CCD Debit Transactions Disclosure Wishful Thinker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Unless you want to deal with a customer and their lawyers, why would you not want it covered in your contract. That being said, there are a ton of pieces of depositor contract langauge that is not required by any law or regulation and is or is not used by various institutions. It is just a matter of deciding what langauge is appropraite for your institution in managing the relationship and legal risks.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1706736 - 06/05/12 04:20 PM Re: ACH - CCD Debit Transactions Disclosure rlcarey
Wishful Thinker Offline
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Joined: Dec 2008
Posts: 77
Thanks for your input. I appreciate it.

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