4/1/2020
The Nacha Rules require an RDFI to accept a consumer’s Written Statement of Unauthorized Debit (WSUD) and also require that the WSUD be signed or similarly authenticated.
Nacha issued ACH Operations Bulletin #5-2020 on March 27, 2020, stating that in light of the current need for many RDFIs to reduce on-site staffing levels, and the physical distancing requirements that currently apply to many people, Nacha will not enforce the signature/similar authentication requirement until further notice.
Additional things that RDFIs can do and should understand:
In light of the current need for organizations to reduce on-site staffing levels, Nacha issued an ACH Operations Bulletin to provide temporary relief from deadlines for delivery of certain records that are required under the Nacha Rules.
Under the Nacha Rules:
Nacha understands that these deadlines may cause a challenge in the current environment. For the duration of the National Emergency concerning the coronavirus, Nacha will refrain from recommending enforcement penalties for cases in which a PoA, Source Document/item, or WSUD is provided after the existing 10 Banking Day time frame but within 20 Banking Days.
Nacha encourages ODFIs and RDFIs to cooperate and to fulfill these obligations under the Rules as quickly as circumstances permit. ODFIs and their Originators should be mindful that utilizing a longer timeframe for providing PoAs could lead to an increase in returns based on claims of unauthorized entries. However, the relief provided by Nacha will allow ODFIs, their Originators, and RDFIs to adapt to the new operating environment without risk of enforcement penalties.
Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult a professional.
Questions?
Staying in compliance can be challenging, so if you have any questions or need assistance, email paymentadvisors@saltmarshcpa.com or a member of our Financial Institutions Team so we can help.
About the Bank Advisors
The Bank Advisors at Saltmarsh have provided audit, tax and consulting services to a wide range of financial institutions since our founding in 1944, making it the firm’s largest specialty practice and industry of focus. Our Financial Institution Advisory Group has the talent, expertise and insight to help you and your institution thrive. Our team members are also industry leaders who have the knowledge and experience to provide you with unparalleled service and guidance.