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Written Confirmation for EFT Errors

Answered by: 
Brian Crow
David A. Dickinson

Question: 
In most cases, when an EFT error (ACH) is reported to us, the investigation is initiated immediately and completed within 10 days. Our bank requires written confirmation for all EFT errors that are reported. We realize that without written confirmation, it does not delay the initiation or completion of the investigation. However, what are our requirements for crediting if the customer does not give us written confirmation within 10 days? Do we have to follow the provisional credit rules? Or do we just let the reported error “hang” until we get that written confirmation?
Answer: 

Answer by Brian Crow: If you have completed your investigation within 10 business days, Reg E requires that you correct the error within one business day of completing your investigation whether or not you have received written confirmation. There is no provisional credit to delay as you are issuing final credit.

Answer: 

Answer by David Dickinson: Section 205.11 and Section 205.6 both govern error resolutions. It sounds like you understand most of those rules, but may not be in compliance with all their requirements.

If you don't receive written confirmation, you don't have to give provisional credit. [Section 205.11(c)]. However, you cannot require written confirmation for EFT errors. If the customer doesn't provide written confirmation, you still must investigate promptly and provide final credit one day after completing the investigation, if the customer is due the funds.

First published on BankersOnline.com 7/11/11

First published on 07/11/2011

Filed under: 
Compliance
Technology
Filed under compliance as: 
EFT
IT
Filed under technology as: 
EFT
IT

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