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NACHA Rule OR7 2.3.2.5 (b).

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Question: 
My question pertains to NACHA Rule OR7 2.3.2.5 (b). We allow our consumers to originate transactions to an external bank. We send two micro deposits to the external account which they must verify. My question is if for some reason the consumer sets up an external account fraudulently and the external FI requests a copy of the authorization what are we required to supply to the FI to satisfy this requirement?
Answer: 

As to the micro deposits, no authorization is required since the Originator and the Receiver are natural persons (the same natural person, in this case). OR 2.3.2.1 - Credit Entries

Once the consumer is up and running with ACH entries, it's possible that both credits (transfers from his account with you to his account at the other bank) and debits (transfers in the other direction) could be originated. As noted, the credits would not require an authorization by the Receiver. If the RDFI were to ask for a copy of the authorization for a debit entry to the customer's account at that bank, you could provide an extract from a log of customer-generated ACH entries as evidence of the authorization, or you could simply provide a copy of the customer's request for ACH generation access to accounts in his name at other banks. I think that will show that the individual (who will be the Receiver at those banks) provided the authorization.

First published on 04/13/2015

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