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Understanding Nacha's "60 day" extended return rule

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Question: 
When I have sent the request to return an ACH debit a customer disputed and it was within Reg E 60 days from the statement date we have been challenged on the return. Are we violating Nacha or Reg E when we return the ACH when it's past 60 days from posted, but not 60 days from statement date?
Answer: 

Submitting a return of an ACH debit that is more than 60 days old (measured from its Settlement Date) is not permitted by Nacha Rules, and the ODFI has the right to refuse the return and send it back to you using a return code of R68 (Untimely Return). Depending on the nature and timing of the consumer’s claim that the ACH debit was not authorized, you may have to reimburse the customer for a transaction that is too old for you to send back to the ODFI.

First published on 08/04/2024

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