Answer:
Under Regulation E, you CANNOT require a consumer to provide a written statement of unauthorized debit (WSUD) as part of a claim that an ACH item was unauthorized. You can and should ask for a WSUD as documentation for an ACH return of many, but not all, unauthorized ACH debit entries. But the ability to return an ACH debit entry with or without a WSUD on file is separate from compliance with the rules covering the Regulation E claim.
Learn more about John Burnett’s Unauthorized ACH Item claims webinar.