We have a customer that stopped all ACH transactions from a vendor that he is fighting with. The vendor sent him/his business to collections. A collection company (or so he thinks it is a collection company) pulled money out of his business account via ACH coded CCD. We have passed the 24 hour timeline to send it back.

The customer stated that it is not authorized and since we cannot send it back by way of ACH are we still required to give him credit and then try to manually get the money back from the ODFI.

And if we do but are not able to get our money from the ODFI are we just out the funds. I hope this makes sense.

A business account is not covered by Reg E so liability for this transaction is governed by your deposit agreement with the business and state law.

If you wish to investigate the customer's claim further, you may send a request to the ODFI requesting copies of the authorization the Originator relied on to debit the account.

Brian,

Thank you for your response.

Include in your letter that they have 10 days to respond, and if the authorization cannot be provided that they allow you to return the item(s) using R31 - Permissible return of CCD

Perfect. Thanks Happy Gilmore