11/21/2005
I need resources to assist in writing a policy for ACH, Networking and End User computing. Do you know of any sites or resources available?
10/03/2005
We have a customer who is repeatedly wanting to do stop payments on numerous ACH items, such as quick pay day loans. This customer says that these items are not authorized, but is claiming this every two weeks when they are memo posting to her account and making her overdrawn. What are the rules surrounding a situation like this? Can we refuse to do stop payments all together for this customer on this type of items?
08/29/2005
I work for an insurance company and we are about to begin offering EFT for insurance payments. As an insurance company are we bound to Reg E disclosures on our notices?
08/15/2005
With regard to recurring payments made using ACH debits, is it necessary to have a signature on file to authorize recurring ACH payments or is an electronic signature/recorded phone call sufficient documentation?
08/01/2005
We accept ACH debits from our savings accounts. When one comes in that is "NSF" can we charge an "NSF" fee if we properly disclose it on our account charges?
07/18/2005
We have several customers who are getting payday loans from these companies. Then they come to our bank the next month and make a stop payment request for any ACH amount from ABC Company. We are charging them a one time fee. This is taking up a lot of our time in processing. I know we can close their account out after giving them 30 days notice. Can we charge them every time an ACH item hits from that same company? Some of these customer have 4 or 5 payday loan companies they are borrowing from. Do we also need to have them sign an ACH stop payment form stating they have notified the payday company to revoke the ACH coming out of their account?
07/18/2005
We have a business account that's an LLC. The partners on this account would like to electronically debit this account to credit their personal accounts (also held at the bank)? Would you agree that this transaction should be electronic and if so, what documentation should we require? If the answer is to the contrary, then should we require that the customer write a check out of the business account and deposit to the personal accounts?
07/04/2005
We received a levy on a customer who did not have a deposit account with us. However, during the course of our investigation, we learned that his direct deposit for his payroll was going into his wife's account (which is a solo account). I know that Subsection 4.1.4 of the ACH rules allows us to post based on account number alone, but what is our obligation, if any, when we discover there is a discrepancy. Are we required to contact the customer to add the husband to the account? If so, do we return the credit if the change is not made? I have not been able to find a return reason code that fits this scenario.
06/27/2005
06/20/2005
Our branch office took a debit card application from an individual who is not an account owner, but a power of attorney. I am hesitant to consider issuing the card. Am I correct in questioning this?