Returned ACH Transactions

Many of our commercial clients originate ACH files and some transactions get returned for insufficient funds, etc. When an ACH transaction is returned to us, we charge it back to the client’s account, much like we do for returned checks. We have a couple of clients who have asked for an individual ID to appear on our ACH Return Notices, along with appearing on the transaction itself (though DDA and/or Online Banking history), and appearing on the DDA statement. We have a procedure in place that stops this information from printing on the original ACH transaction for consumer clients. Many of them complained, since this field may contain social security numbers. There is no regulation on what has to appear in this field. It may contain a SS number, but may also contain other information. I have seen a mix of things in this field ranging from a blank field, to a person’s name, to a string of numbers and letters that do not mean anything to me. Basically, we hide this field from consumers due to their complaints. The situation I am asking about is slightly different, but I would still like to confirm with you that there are no regulatory or privacy issues. For the custom we are getting ready to ask for, it will show the information that is in this field, it will show it on the actual return notice, it will print it on the statement, and will also appear through DDA and OLB history. The difference here though is that the client who sees this information on his return notice and on hus statement is the same client who populated that field, so I do not think it will be an issue, since it is information that the client provided to us originally, and that he already has access to it, but I wanted to double check before we get too far down this road.