Our bank has heard that NACHA is going to start imposing a $18.00 fee for every unauthorized payment transaction processed. Is this true and if so do you know when it will go into effect?
My question concerning Reg E is....Are we allowed to charge the customer for furnishing an affidavit and acquiring signature claiming unauthorized ACH charge?
Where can I find clear, concise definitions and descriptions of RCK, XCK, POP, ARC, WEB, and TEL transactions? I want something I can distribute to our staff so that they can easily answer clients questions and resolve error disputes.
We recently implemented Internet Banking for our customers. We would now like to enhance that service with online bill pay. We've had customers asking if we will also offer the ability to write checks on line. Is there a difference between on-line bill pay and writing checks on line?
We recently had ACH training and found out that according to NACHA rules, we were doing stop payments incorrectly for ACH items. Are the NACHA rules the only governing force for ACH transactions, or is there some overlap with Reg E? Before we change our internal policy we want to be sure that strictly going by NACHA rules won't have us violating Reg E.
A title company, who is a customer of ours, closed a loan on July 9, and received an ACH of a large sum in relation to that transaction. On July 21, the bank that sent the original ACH debited our customer's account for the same amount (allegedly because of identity theft/fraud on their end). We cut the customer's statement on July 31, and mailed it to them August 3. The customer also has daily access to his/her account to check their transaction history. On October 1, the customer called the bank and demanded the money back from us, and stated we were liable for it because they notified us within 60 days. I know it does not fall under Reg E because it is a business, and I think we're OK under ACH because the 60 day clock is a settlement date, not a statement date. Am I wrong or am I missing something? Isn't their claim really against the bank that originated the transaction?
I was wondering if we need to notify our customers about the conversion of checks as part of compliance? Some vendors that change the customers checks in RCK or ARC ACH format charge the customers, and we are getting calls saying that these are unauthorized. Does anyone know about sending marketing materials to explain this to the customers and make them aware of RCKs and ARC transactions?
If a check is issued to a retailer who converts it to an electronic entry and the customer wants to place a stop payment on the check, which stop payment form should be used - a check stop payment form or an ACH stop payment form?
When a customer writes a check and then wishes to place a stop payment order on it, if the check is erroneously converted to TEL transaction, the ODFI does not know this is an error and processes the transaction. Is a stop payment valid on TEL and WEB transactions that may be erroneous or even fraudulent?
Under Reg E, must a bank record every time a customer has a problem with an ATM or Debit card, ACH, ATM machine, computer or telephone transaction? We outsource our card processing and anytime there is a dispute, we have the customer (or non-customer if they used our ATM and encountered a problem) indicate in writing what the dispute involves. At that point, we fax the dispute to our card processor and they research the transaction. This sometimes takes up to 120 days. We do not credit until we have heard back from the card processor. Is this not past the time frame allowed under Reg E? If a customer is having trouble getting a preauthorization on a debit card transaction, we never get the customer to put it in writing to us. Should we?