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Late ACH Returns

Answered by: 
Randy Carey

Question: 
We have an ACH compliance question. One of the credit unions that we audit has reached out regarding an ACH return request. They received the request on 9/1/2022; however, the effective date of the transaction was 7/22/2022. This was returned R06-Returned per ODFI's request and appears to be outside of the requirements for the time of return. The question is: 1) Does the CU have to honor this return and 2) if so, is it acceptable to honor the return via fax? We are thinking that it would need to go through the Federal Reserve?
Answer: 

There is not enough information here to understand what is happening, but once an ACH entry is received and posts to an account at a RDFI, any request for reversal by the ODFI is optional and should be accompanied by a hold harmless agreement.

First published on 10/16/2022

Filed under: 
Compliance
Filed under compliance as: 
ACH
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