Answer:
Under Regulation E, you can’t require a consumer to provide a written statement of unauthorized debit (WSUD) as part of a claim that an ACH item was unauthorized. You can and should require a WSUD as documentation for an ACH return of most, but not all, unauthorized ACH entries. But the ability to return an ACH entry with or without a WSUD on file is separate from compliance with the rules covering the Regulation E claim.
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Learn more about John Burnett’s webinar Managing Unauthorized ACH Items