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Reg E & Unauthorized ACH Transfers

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If a customer contacts the bank stating there has been ACH transfers coming out of their account that they never authorized. Would the bank be required to resolve the problem by following Sec. 205.11 of Reg E - Procedures for resolving errors?

Yes, if the account in question is a consumer account. If the claim involves multiple transactions, you should also review the limits on consumer liability for unauthorized EFTs in section 205.6 of Regulation E. The amount the consumer may recover will be limited by subsection 205.6(b)(3) to transactions occurring before the end of the 60-day period counted from delivery of the first statement showing one of the series of unauthorized EFTs.

First published on 9/22/08

First published on 09/22/2008

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