Answer:
Answer by Randy Carey:
Refer to 12 CFR 1005.9(b).
Answer:
Answer by Brian Crow:
Debit Card transactions that your institution is receiving as an ACH transaction are most likely connected to a "decoupled" debit card, that is a card issued by a third party that your customer has elected to connect to their account. Reg E 1005.14(b)(1)(iv) requires the issuer of the debit card to transmit sufficient information via the ACH network to enable you to comply with the periodic statement requirements of 1005.9(b).
Reg E 1005.14(c)(1) states that the account holding institution does not have any liability under Reg E if the card issuer fails to provide all of the required information. All your institution can do with these transactions is post the ACH transactions on the periodic statement based on the information that you received in the clearing file.
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