#2289204 - 09/28/23 01:02 PM
Re: ACH Standard Entry Class Use - Liability Question
Anonymous
|
10K Club
Joined: Jul 2001
Posts: 85,417
Galveston, TX
|
If an RFDI sends an R05, or R10, the ODFI cannot properly re-debit the receiver's account on the basis of the original authorization (if any), unless and until the receiver enters into a new authorization with the originator. While that might not be as complicated as it sounds, it still is not the same as simply taking the liberty of 'correcting' the entry and running it again unannounced. I still do not understand the issue from an ODFI perspective. Your customer, that is the originator, made a mistake or did this on purpose. The consumer on the other end claimed the transaction was unauthorized. It is up to your customer to abide by the NACHA rules, of which, you are required to provide them a copy of, in order to obtain a reauthorization to continue any ACH activity with the consumer that they are trying to debit. Maybe their customer accidently gave them the wrong account number, etc., but its' up to them to figure it out. If I had an originator for which I was getting more than a couple of R05s or even R10s or R11s over a short period of time, I would be having a sit-down visit with this customer and determine whether or not to sever the relationship. Why is this risk any different than any other risk for unauthorized transactions that are presented to an ODFI by an originator. That is why you are required to do a detailed risk analysis prior to offering this product.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
Reply
Quote
Quick Reply
Quick Quote
|
|
|
|
|