Unauthorized/Disputed ACH - Notice Required?

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Question:

Does the bank have to provide a notice outlining the action taken and/or results of the investigation as Reg E requires on debit card disputes when a customer reports an ACH transaction as unauthorized or disputed?

Answer:

Answer by John Burnett:Regulation E does not discriminate between ACH and debit card transactions when it comes to applying its requirements for handling error resolution. ACH and debit cards are both electronic funds transfers and if posted to a consumer deposit account they are subject to Reg E's section 205.11.

Answer:

Answer by Patricia Cashman:This is where your customer contact personnel must know how to interview customers to obtain the necessary information. Reg E covers unauthorized ACH transactions just as it does a debit card dispute (205.11(a)(1)(ii)). An example of an unauthorized ACH would be when your customer tells you that there was an ACH debit on his statement that he either did not authorize or was for an incorrect amount. A disputed ACH transaction would be covered under the ACH rules. A disputed ACH transaction would occur if the consumer had authorized the transaction and then decided that they wanted to cancel because the facility was not up to par.

First published on BankersOnline.com 9/22/08