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In Response To:
Thread Starter: Anonymous
Title: Re: NACHA / ACH Purpose (SEC) Codes

Thank you for your prompt response and consideration.

We have a consumer deposit account holder whose account has been debited by an originator with the CCD entry class code.

I realize that, even in this case, the transaction could have been timely returned if done within the "extended" 60-day+1 business day return window.

Where it gets complicated, however, is that our customer asked us to return this item many months after the transaction settled on the account.

We hope to convince the ODFI, a major national institution, to accept a late return (R31, or perhaps without entry if not through FedACH). We believe the CCD against a consumer account breaches the warranty between the ODFI and RDFI.

Our early attempt at a late using just the R05 return, led to an automatic rejection-- and a brief follow-up that the originator believes the underlying transaction was otherwise properly authorized by our customer.

And that's where the other part of my question comes in.

Since this appears to be a future point of contention, can we argue also that the use of an improper SEC code, in and of itself, rendered the transaction unauthorized (or, at least, "not properly authorized"), without even having to become a middleman in whatever dispute exists between our customer and the originator as to authorization?