I'm seeing one company / vendor in particular that offers an online service for consumers and seems to be doing (egregiously) all its ACH billing debits via CCD (not PPD). I know the NACHA rules kind of revert back to the 60 calendar days (vs 2 business?) to correct / protest the CCD debit if it's to a consumer account, but beyond that is this technically allowed? Not sure what benefit you'd have by choosing a B2B-oriented standard entry code over the the preauthorized payment and deposit (PPD) typically done with consumers?

It appears that they are knowingly in direct violation of NACHA rules. I would consider reporting them.

Thx, noted. I'm still trying to get a full copy of the NACHA rules since I don't work in the ACH area of my bank. It seems like the light version of the rules I *can* see seems to acknowledge that CCD can happen on consumer accounts (and has language about a kind of reversion to the consumer's 60 days to seek recourse). But, that might be more an acknowledgement that nothing is perfect, rather than tacit condonement.

Total aside: I cannot believe that if I have a business account, get CCD'd fraudulently I apparently only have two business days max (less really since I have to get my bank to initiate the reversal) or I could eat it. I'm surprised there is not more rampant CCD fraud (like enough that it hits the mainstream media or even just trade media); admittedly I could have missed the stories.

Businesses are expected to monitor their activity more closely. Since these aren't covered by Regulation E, it is subject to the account agreement between the business and the bank so even if a business were to try and sue or go to the media, they would lose in court. Personally, I review my business account activity online every single day.

and a business can also sign up for a host of treasury services that are not normally offered to consumers, such as ACH positive pay that can alert them to transactions that they then have to agree to pay or return by a specific time each day

Not disagreeing about the prevailing presumption that business = more financial savvy and vigilance. Though, it's also a broad brush. Some businesses with business accounts are pretty small. 5 or fewer employees, perhaps only one employee. A small plumber who's literally down in the trenches is not going to be getting treasury management and yet be exposed to full account drainage.