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Accurate Signed Auto Payment Authorization-NACHA

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Question: 
Is it a NACHA violation if the bank does not have an accurate signed auto payment authorization form on file? For example, customer has signed a document authorizing the bank to pull payments from account 1234567, but the bank has transposed numbers and is attempting to pull from 1234576.
Answer: 

I can't say if it is a NACHA violation but I believe it prefers written evidence authorizing the debit. It appears from the question that the bank transposed the account number. At this point I would believe the bank has a past due loan (either because the account number was nonexistent or the payments from the wrong account were reversed). The bank needs to contact the borrower and waive the late fees if the account is paid current (funds should be waiting) or make a payment plan. At the time the authorization can be corrected and initialed or a new and correct one signed. In that the bank appears to require these it should do so again.

First published on 09/17/2017

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