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Handling Non-receipt of ACH over the Phone

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Question: 
We're being requested by the US Treasury to handle, over the telephone, amongst other things:* non-receipt of ACH credit claims, * request for account ownership info, and others that they want to give to us. We do not have to resolve the actual issue real-time over the phone but at a minimum, take in their claim/request. They're referring to the Social Security Act (Section 1441, Title 26, Title II the Railroad Retirement Act of 1974 and the Right to Financial Privacy Act (12 U.S.C. 3413 (K)) and saying that we're required to comply. Are you familiar with this and what are we required to do?
Answer: 

In the future, whenever anyone says you are required to do something, ask for a citation to law or regulation. This particular caller may say that it's in your customer's interest or even the bank's interest to assist them, but is not in a position to cite you to a law or regulation that requires you to disclose the existence of the customer relationship or provide account information over the telephone. At a minimum, in order to gain some credibility, the caller should have referred you to the Treasury Department Financial Management Service's Tele-Trace program which indicates:

If the payment has not been returned, FMS will call the RDFI to inquire about the reason for nonreceipt.

Obviously, accepting this practice lowers a financial institution's natural thresholds to phishing. However, I am compelled to consider the effects a blanket refusal would have on the customer.

Consider:

  1. Routing all such calls to the same person within your institution.
  2. Asking the caller for his or her full name, employee number(?) and the office where he or she is located.
  3. Calling the person back at the publicly listed number for that office.
  4. Asking for all the identifying information he or she has on your customer including any prior payments. Use it to verify that you are talking about the same person.
  5. Reviewing the account for payments and focus on the information the caller actually needs. This is neither a fishing or a phishing expedition.
  6. Completing a worksheet with the relevant information, including the name and phone number of the caller, and sending a copy to the customer.



First published on BankersOnline.com 9/11/06

First published on 09/11/2006

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