ACH Originator - Notice of Change in Amount

I receive my phone bill in the mail every month about one day before my automatic debit is taken out of my account. Sometimes the amount changes depending on what type of activity I had for that month.

In reading subsection 3.4.1 of the NACHA Rules book - shouldn't my telephone company be sending me a notice 10 days before this debit is taken out of my account?

I believe you mean 3.3.1, but if you look at 3.3.2, I wonder if your contract with the phone company is covered by that? Basically, it allows them to debit the accoutn as long as it falls within a certain range. Take a look at the authorization you originally granted them.

Our bank originates loan pmts for our loan customers and the loan amounts change every year depending on escrow account changes. Instead of having the customer complete a new ACH authorization every year, is there standard verbiage we can add to our authorization that would cover this (as Happy mentions above)?

Unless you can predetermine the range of amounts to be debited at the time of getting the authorization, that tactic won't work (and given the nature of tax and insurance escrows, estimating the range is somewhere between slim chance and fat chance).

The requirement, then, is to provide notice when the payment amount will change. I think you can give that notice once, ten days before the first of the new series of payments, rather than before each payment. As for timing, sending the notice with the annual escrow analysis might be smart, since that's when you determine the new escrow payment amount.

Since the escrow analysis shows what the old payment is and what the new payment will be if they don't pay the shortage, would this be sufficient as the "notice of change in amount"?

Only if it clearly says on it that the charge to the customer's account is going to change. If you're using a standard escrow analysis notice, that's probably not there.