Is there any scenario in accordance with Regulation E when the originating bank has the ability to return/reclaim the funds for an ACH claimed as unauthorized by their account holder?
Do we need to follow the Reg E rules when a customer signs an affidavit for unauthorized or revoked ACH debits? We currently issue immediate credit once the affidavit is completed. Should we be doing something different? Do we need to use the Reg E guidelines or just the NACHA guidelines?
Relative to Reg E, a client notified the bank that unauthorized charges were posted to his checking account on 1/12/06. The charges were posted 10-27, 10-28, 11-3, and the statement was cut 11-22. He notified us within 60 days of the statement, but NACHA states 60 days from settlement date. We originally provided provisional credit, but when the claim was denied from ACH, we took provisional credit back from the customer. I feel the bank is in error and a refund is due to the customer since regulation states 60 days from statement. Do you have an opinion?
With paper checks converted to electronic checks, how should E-checks requiring two signatures (no longer can verify that two signatures are there) be handled?
What are our bank's options in terms of returning an electronic check that posted 15 days ago to a customer’s account which the customer did not authorize?
I attended a seminar Wednesday 1-11-06 on ACH returns. I have a question regarding customer notice to the bank of unauthorized ACH entries. You say the customer must notify the bank within 15 days of statement delivery, but what we are reading in Reg E indicates the customer has 60 days to report unauthorized entries. Please clarify.
Are there different ACH and/or VISA rules for error resolution, or do the timelines and requirements of Reg E apply?
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?