Most Popular Operations Content
Understanding Nacha's "60 day" extended return rule
08/04/2024
When I have sent the request to return an ACH debit a customer disputed and it was within Reg E 60 days from the statement date we have been challenged on the return. Are we violating Nacha or Reg E when we return the ACH when it's past 60 days from posted, but not 60 days from statement date?
CFPB's proposals to cut big banks' OD fees
07/28/2024
When is the CFPB likely to issue a final regulation making banks over $10 billion in assets cut their overdraft fees back to a breakeven amount or start treating overdrafts as extensions of open-end credit subject to Regulation Z?
Disclosing "posting order" when explaining when OD fees may be charged
07/28/2024
If we elect to update our disclosures on the circumstances that may trigger overdraft charges, do we have to disclose the order in which we post debit and credit items to deposit accounts?
Identifying "protected funds" under Treasury's garnishement regulations
07/28/2024
Two of our depositors receive direct deposits of both VA and Social Security benefit payments to their joint checking account. We received a garnishment order naming one of them as judgment debtor. When we looked back over the past two months’ account activity, we found two direct deposits for Social Security benefits and two for VA benefits. These customers routinely move their SSA and VA deposits into their savings account soon after they are received, and appear to meet their monthly bills using monthly IRA disbursements. Can we treat the SSA and VA funds in the savings account as “protected funds”?
Exceptions and audits
07/28/2024
How can exception management impact audits?